VivindaTV Privacy Notice

29th June 2018


Novartis Pharma AG (in 4056 Basel, Switzerland) is responsible for the processing of your personal data on the VivindaTV platform, as it decides why and how it is processed, thereby acting as the “controller”. In this Privacy Notice, “we” or “us” refers to Novartis Pharma AG.

We are processing personal data about you when you are recording to and visiting the VivindaTV platform.

1. Specific personal data to be collected

We will not process your personal data if we do not have a proper justification foreseen in the law for that purpose. Therefore, we will only process your personal data if we have obtained your prior consent or if the processing is necessary to comply with our legal or regulatory obligations.

The information requested for the registration process will be used by Novartis Pharma AG and its affiliates for managing your registration and, based on your consent, for the purpose of personalizing the content of VivindaTV based on the areas of medical interest provided by you during the registration process and for communicating content updates regarding your participation in VivindaTV to attend virtual events. Data will also be used for disclosing Transfer of Value according to the existing laws and regulations in your local country and may be used for any other legal or regulatory obligation, we may have.

2. Specific third parties with whom we share your personal data

We will not sell, share, or otherwise transfer your personal data to third parties other than those indicated in this Privacy Notice.

In the course of our activities and for the same purposes as those listed in this Privacy Notice, your personal data can be accessed by or transferred to the following categories of recipients, on a need to know basis to achieve such purposes:

  • our personnel (including personnel, departments or other companies of the Novartis group);
  • our consultants, suppliers and service providers (including IT system providers, cloud service providers, etc.) and our independent agents or brokers (if any);
  • our business partners who offer products or services jointly with us;
  • any third party to whom we assign or novate any of our rights or obligations;
  • our advisors and external lawyers in the context of the sale or transfer of any part of our business or its assets.

The above third parties are contractually obliged to protect the confidentiality and security of your personal data, in compliance with applicable law.

Your personal data can also be accessed by or transferred to any national and/or international regulatory, enforcement, public body or court, where we are required to do so by applicable law or regulation or at their request.

The personal data we collect from you may also be processed, accessed or stored in a country outside the country where Novartis Pharma AG is located, which may not offer the same level of protection of personal data.

If we transfer your personal data to external companies in other jurisdictions, we will make sure to protect your personal data (i) by applying the level of protection required under the local data protection/privacy laws applicable to Novartis Pharma AG, (ii) by acting in accordance with our policies and standards and, unless otherwise specified, (iii) by transferring your personal data on the basis of standard contractual clauses approved by the European Commission or the Swiss Federal Data Protection and Information Commissioner respectively, when transferring your personal data from Switzerland or the European Economic Area (i.e. the EU Member States plus Iceland, Liechtenstein and Norway, the "EEA"), to a country which does not offer the same level of protection of personal data. You may request additional information in relation to international transfers of personal data and obtain a copy of the adequate safeguard put in place by exercising your rights as set out in Section 6 below.

For intra-group transfers of personal data to our group companies, the Novartis Group has adopted Binding Corporate Rules, a system of principles, rules and tools, provided by European law, in an effort to ensure effective levels of data protection relating to transfers of personal data outside the EEA and Switzerland. Read more about the Novartis Binding Corporate Rules by clicking here. In all cases, Novartis Pharma AG is responsible for management of your personal information.

3. Duration of storage

Novartis will not share your information with anyone who is not directly connected with this purpose. Information will be stored for a period of 24 months after your last access to VivindaTV.

4. Cookies and other similar technologies

Novartis will also gather statistics of usage of the VivindaTV portal in an aggregated form and not related to any individual usage.

The following specific types of cookies and/or other tracking technologies are used on VivindaTV:

We may use “user interface customization cookies”. Once set, you do not need to specify your preferences again on another visit to the site.

We will place an “authentication cookie” on your computer. This allows you to leave and return to VivindaTV web sites without re-authenticating yourself.

We will place “video player cookies” on your computer. These cookies are used to store data needed to play back video or audio content and store the user’s preferences.

Novartis likes to understand how visitors use our websites by using web analytics services. They count the number of visitors and tell us things about the visitors’ behaviour overall – such as the typical length of stay on the site, the average number of pages a user views, what media content a user consumes and similar behavior and viewing patterns. For this purpose we place a “first party analytics cookie” on your computer. Information collected through these cookies are not used to identify users but in as aggregated information only so that a user may not be identified.

Any data collected by using these cookies may be stored and managed by third parties, who act for or on Novartis behalf, for further processing in accordance with the purposes described here in the Privacy Notice

Please see our cookie policy for more information: https://www.vivindatv.com/content/vivinda/en/econgress/footer-links/about-cookies.html

5. Protection of your personal data

We have implemented appropriate technical and organisational measures to provide an adequate level of security and confidentiality to your personal data, taking into account the nature of the data and the risk of processing such data.

The purpose thereof is to protect it against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing.

Moreover, when handling your personal data, we comply with the following obligations:

  • we only collect and process personal data which is adequate, relevant and not excessive, as required to meet the above purposes;
  • we ensure that your personal data remains up to date and accurate (for the latter, we may request you to confirm the personal data we hold about you and you are also invited to spontaneously inform us whenever there is a change in your personal circumstances, so we can ensure your personal data is kept up-to-date).

6. What are your rights and how can you exercise them?

You may exercise the following rights under the conditions and within the limits set forth in the law:

  • the right to access your personal data as processed by us and, if you believe that any information relating to you is incorrect, obsolete or incomplete, to request its correction or updating;
  • the right to request the erasure of your personal data or the restriction thereof to specific categories of processing;
  • the right to withdraw your consent at any time, without affecting the lawfulness of the processing before such withdrawal;
  • the right to object, in whole or in part, to the processing of your personal data;
  • the right to object to direct marketing communications; and
  • to the extent applicable, the right to request its portability, i.e. that the personal data you have provided to us be returned to you or transferred to the person of your choice, in a structured, commonly used and machine-readable format without hindrance from us and subject to your confidentiality obligations.

Please note however that, in certain circumstances, your refusal to accept cookies or your browser settings may affect your browsing experience and prevent you from using certain features on our websites or apps.

If you have a question, if you are not satisfied how we process your personal data or if you want to exercise the above rights, you may send an email to global.privacy_office@novartis.com. When contacting us, please add a description of your relationship and/or your interactions with us. If you wish to receive information related to your personal data, please also add a scan of your identity card for identification purpose, it being understood that we shall only use such data to verify your identity. When sending us such a scan, please make sure to redact your picture and national registry number or equivalent on the scan.

In any case, you also have the right to file a complaint with the competent data protection authorities, in addition to your rights above.

7. How will you be informed of the changes to our Privacy Policy?

You are informed about future changes or additions to the processing of your personal data as described in this Privacy Policy in advance through our usual communication channels (e.g. by email or through the VivindaTV website).