Privacy Notice
for events and communication
The purpose of this Privacy Notice is to inform you about the processing of your personal data in connection with your participation in events organized by Swixx BioPharma and our communication with you.
Who is the data controller of your Personal Data?
A data controller is a Swixx BioPharma company indicated as the event organizer, including its contact details, in the invitation or/and in registration platform/website (hereinafter “SWIXX” or "Data Controller").
What are the purposes and legal grounds for processing your Personal Data?
Due to SWIXX activity in pharmaceutical industry, where transparency and ethical standards are significant valuable and which are regulated by the laws, EFPIA or local associations practice codes, all interactions with healthcare professionals, their associations and patient organizations must be properly documented. In order to organize the particular event, maintain list of the event’s participants prove the event’s content compliance with all applicable regulations and a fact that the event took a place, as well as to publicly present the held event or/and SWIXX activities, SWIXX may process your following personal data (hereinafter “Personal Data”):
- Full name, specialty, country, hospital/institution, username, password is processed for registering yourself for attendance in a particular event. The Personal Data is processed under your consent (GDPR art. 6.1a). Please, note if you will not provide those personal data, Swixx Biopharma will not be able to ensure your participation in the event.
 - Name, surname, title and workplace, arrival and departure time, flight/bus/train number, work email address and phone number, dietary requirements, personal identification document (copy or data), but only where such document or information is required for visa or cross-border travel purposes - may be processed in order to organize the on-site event, where SWIXX shall arrange particular services related to your participation in the on-site event (e.g., to arrange transfer services, book hotel accommodation and catering, issue an invitation for getting a visa etc.), as well as to properly maintain bookkeeping and report financial expenses. This Personal Data is processed based on SWIXX legitimate interest (GDPR art. 6.1.f), namely, to organize the Event considering the number of attendees, arrange accommodation, catering, transfers, activities, etc., and to report and audit expenses in accordance with the internal rules of the Swixx Biopharma Group of Companies, thereby ensuring reasonable use of SWIXX financial funds. Information about dietary requirements is processed based on your consent, expressed by voluntarily providing such information to SWIXX (GDPR art. 6.1.a and art. 9.2.a). Personal Data processed for the purposes of bookkeeping, reporting and auditing of expenses may also be processed under a legal obligation (GDPR art. 6.1.c), where applicable financial accountability laws require the processing of such Personal Data.
 - Name, surname, field of expertise (specialization), workplace, signature. This Personal Data is processed based on GDPR 6.1.c, i.e. legal obligation arising from the laws governing medicinal products advertisements or/and GDPR article 6.1.f (legitimate interest) to maintain a participant list as assurance of reasonably and appropriately used SWIXX financial funds and as proof that healthcare professionals participated in the event, who have a right to receive medicinal products promotional information.
 
If you will not provide your aforementioned personal data, SWIXX may not be able to secure your attendance at the event properly.
- Image, voice records adding your name, surname, workplace, title, specialization next to the record or tagging your social network account in order to provide the event’s memories for the event’s participants, as well as to publicly (internally and externally) present the held event and SWIXX activities on SWIXX website (www.swixxbiopharma.com), social network accounts or in presentations introducing SWIXX, or at any newsletters, press conferences, scientific events, congresses and other public or private events, in specialized publications or on the platforms/applications of Swixx or of Swixx Biopharma Group of Companies listed at https://www.swixxbiopharma.com/en/countries/ or those of SWIXX's collaborators in order to promote the event to the public, including on the Internet - e.g. on web pages, intranet pages, social networks, in the presentations introducing SWIXX, etc. - in the media, radio or TV broadcasts, etc.), in the digital format or printed. For this purpose mentioned Personal Data may be processed based on the participant’s consent (GDPR art. 6.1.a), unless the legitimate interest may be applied pursuant to local laws (a legitimate interest is to assure compliance and transparency of the Event where HCPs are involved, as well as to promote SWIXX and its activities internally and externally) or pursuant to the concluded agreement with you, where your filming, audio recording or made photos is in scope of the concluded agreement, e.g. concluded agreement to prepare and record a video lecture for future use.
 
If you do not wish to be filmed, photographed, or otherwise recorded, please wear a clearly visible sticker during the event. If you are participating in the online event, please switch off your camera and mute your microphone.
- Full name, email address, specialty, country, hospital/institution, as well as the answers you provide in the survey, are processed to carry out surveys about the event, collect feedback, and assess participants’ satisfaction with the event. This Personal Data is processed based on SWIXX’s legitimate interest (GDPR art. 6.1.f) namely, to improve the organization of events, better reflect participants’ expectations, and enhance their experience when interacting with SWIXX.
 - Full name, email address, specialty, country, hospital/institution are processed to contact you personally and/or by electronic means to provide you with professional information (promotional, scientific, medical, educational), invite you to participate in professional and educational activities, and send you information about our products and services, as well as products and services of our partners, whose products are distributed / promoted / represented by SWIXX, and to seek your opinion about your experience using different treatment methods. Personal Data is processed based on your given consent (GDPR art. 6.1.a).
 
What is the data retention period?
  We  usually keep personal data processed on legal grounds other than consent for up  to 10 years, unless a longer or shorter period is required by law. This may be  necessary, for example, to meet document retention obligations or to protect  our legal rights.
  Personal  Data processed on the basis of your consent will be retained until you withdraw  your consent, unless SWIXX determines that the purposes have been achieved and  deletes your Personal Data. Please note that, notwithstanding the withdrawal of  your consent, SWIXX may be required to retain certain Personal Data in order to  establish, exercise, or defend legal claims in court.
Who are the recipients of your Personal Data?
SWIXX protects Personal Data by using technical and organizational measures, but due to SWIXX activity Personal Data may be transferred to following recipients:
- SWIXX related companies, which are listed at https://www.swixxbiopharma.com/en/countries/;
 - SWIXX partners, which products SWIXX distributes / promotes / represents, and which are listed at https://www.swixxbiopharma.com/en/partnering/;
 - Social media networks including but not limited on SWIXX social network accounts, e.g. LinkedIN, SWIXX website or may be used for different materials prepared by SWIXX, SWIXX affiliates or SWIXX partners to present its activity;
 - Consultants, IT and other service providers enabling them to perform their functions.
 
Taking into account that your personal data might be processed not only within the EU, but also in Switzerland and non-EU countries, we would like to inform you that your data will be protected on the same level as in the EU based on following safeguards: a) personal data transference between Swixx Biopharma Affiliates or other entities located in Andorra, Argentina, Canada (only to commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Republic of Korea, Switzerland, the United Kingdom under the GDPR and the LED, the United States (commercial organisations participating in the EU-US Data Privacy Framework) and Uruguay shall be based on the relevant European Commission decision of providing adequate protection of personal data (a particular decision can be found at https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en); b) personal data transference between entities which are not located in the EEA and where is no the European Commission decision of providing adequate protection of personal data, shall be based on the European Commission implementing decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter referred as to the “SCC”); c) other applicable safeguard referred in GDPR Chapter 5.
What are data subject rights?
In relation to Personal Data processing, you as a data subject have following rights:
- a right to be informed how and why SWIXX uses your Personal Data. We are implementing this your right by this Privacy Notice;
 - a right to request a copy of the Personal Data that SWIXX holds about you and details of how SWIXX uses that information;
 - a right to amend or rectify your Personal Data if any of the information held about you is incorrect or out of date;
 - a right to Personal Data portability;
 - a right to request erasure of your Personal Data;
 - a right to demand that SWIXX ceases the processing of your Personal Data or that SWIXX restricts the processing of your Personal Data;
 - a right to withdraw a consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. This right may not apply if there are other legal justifications to continue processing or SWIXX needs to retain certain personal data where required or permitted under applicable law;
 - a right to get a copy of the appropriate or suitable safeguards used for Personal Data transfer to third countries or international organization;
 - a right to to lodge a complaint with the supervisory authority competent for the event organizer. Contact details of the relevant authorities are available at: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en. If the event organizer is Swixx Biopharma AG, the supervisory authority contact details are available here: https://www.edoeb.admin.ch/en.
 
How can you exercise your rights or get more information about the processing of your Personal Data?
If you would like to make a request to access, review, correct, delete or port the Personal Data SWIXX has collected about you, to assert a right with regard to your Personal Data, or to discuss how SWIXX processes your Personal Data, please contact SWIXX at data@swixxbiopharma.com. SWIXX will respond to you not later than within 1 calendar month.