For healthcare professionals

Information concerning the processing of your personal data in the context of Thea promotional activities

Following the entry into force of the European Regulation on the Protection of Personal Data, known as the GDPR1, Thea Pharmaceuticals Limited (“Thea”), as controller, having the registered office Thea Pharmaceuticals Limited, IC5 Building, Innovation Way, Keele, Newcastle, England, ST5 5NT, e-mail: privacy.uk@theapharma.com informs you through this letter about the use of your personal data.

This notice describes our practices when using the personal information of healthcare professionals for the purposes of marketing and other promotional activities.

For further information regarding how we process the personal information of all of our business contacts, including healthcare professionals, please see our Website and Business Contact Privacy and Cookies notice on our privacy page.

1. Why do we collect and process your data?

Thea collects and processes certain data relating to you for certain purposes: in order to provide you with the most appropriate information for your specialty area, in particular medical information; to organise Thea’s canvassing of healthcare professionals; for your registration to events; to submit to any relevant professional body in order to be able to issue CPD/CET certificates; our legitimate interests such as promotion of Thea products and events and other relevant promotions; to develop our network of health professionals; and to fulfil our legal and regulatory obligations.

We may use your personal data for related purposes compatible with those listed above. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

2. What data is collected and processed?

We collect the following personal data:

  • Identity: surname, first name, gender, registration number
  • Various details concerning your professional activity: specialty, pathologies treated, modality and practice of treatment
  • Professional contact details: workplace address, telephone number, email
  • History of interactions between you and Thea: appointments, meetings, participation in events (including advisory boards), promotional campaigns or programs, visits to our websites and social media, case study submissions.

This data is necessary for us to be able to provide you with relevant and appropriate information.

We will collect the information from you directly, or from the following sources:

  • Thea group companies;
  • Corporate customers and other business partners;
  • Third parties offering commercially available marketing lists, such as IQVIA.

3. How is data processed and stored?

This information is processed securely for the entire period of your professional activity and is accessible to our networks of medical sales representatives, to Thea's authorised personnel and its group companies and affiliates, competent authorities and institutions, authorized sub-contractors and Thea’s providers of additional services such as, but not limited to, financial services/accounting and legal advisory services, as well as to third-party application suppliers where the data and technical solution for data collection and storage are uploaded (for example, our CRM systems).

You can exercise your rights in respect of your data at any time. To do so, please refer to points 5 and 6 of this notice.

4. Legal basis for the processing of your data

We use this information because:

It is necessary for compliance with any legal or regulatory obligations that we are subject to;

This data processing is necessary for the purposes of pursuing our legitimate interests, which are as follows:

  • To promote and improve Thea’s products;
  • To promote and improve our activity, in general;
  • To develop our network of healthcare professionals.

If you require further information regarding our legitimate interests as applied to your personal data, you may contact privacy.uk@theapharma.com

In limited circumstances, such as in the case of marketing, where you have given your consent, we will rely on consent as required under applicable law.

Where we rely upon your consent, you will have the right to withdraw that consent by contacting privacy.uk@theapharma.com

5. The rights you hold over your data:

You may request to exercise the following rights, under the conditions and within the limits provided by the GDPR:

  • right to access: you may receive certain information about the data processing and a copy of the processed data;
  • right to rectification: you may request rectification of inaccurate data or the completion of incomplete data;
  • right to erasure: you may request the erasure of personal data and, in case the personal data have been made public, inform other controllers about the request for erasure;
  • right to restriction of processing: you may request the restriction of the data processing;
  • right to data portability: you may request to receive your personal data in a structured, commonly used and machine-readable format and request the transfer of these data to another controller;
  • right to object: you may object to the data processing in order to stop it. You also have the right to object to processing in order to send you direct marketing;
  • rights related to automated decision-making: you may have certain rights in relation to decisions made solely on the basis of automated processing of your personal data that has legal or similar effects on you;
  • right to lodge a complaint to the supervisory authority: you may lodge a complaint with the supervisory authority if you consider the data processing to be an infringement of the GDPR. In the UK you can make a complaint to the Information Commissioner's Office (Tel: 0303 123 1113 or at www.ico.org.uk)

6. Further Information

For further information regarding our use of personal data, including international transfers, how long we retain your data, security applied to your data and further information regarding your rights, please see our Website and Business Contact Privacy and Cookies notice available on our privacy page.

7. How to exercise your rights or contact us to request information:

If you wish to exercise these rights, you may contact Thea by using the following contact details:

  • privacy.uk@theapharma.com
  • Thea Pharmaceuticals Limited, IC5 Building, Innovation Way, Keele, Newcastle, England, ST5 5NT

Our Data Protection Officer in France is at your disposal to answer your questions at: dpo@theapharma.com or by post: Laboratoires Théa, Données personnelles, Z.I. du Brézet, 12 rue Louis Blériot - 63100 Clermont-Ferrand, France.

Version dated 8 June 2021

[1] The Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.