Santen Eyecare Education - SEE Portal - Privacy Policy

Our commitment to privacy

The Santen Eyecare Education ("SEE") Portal available at https://santensee.eu is operated by Santen S.A. Switzerland. (Santen S.A. Switzerland, Address: La Voie-Creuse 12 1202 Geneva, Switzerland, URL: www.santensee.eu) ("Santen", "we", "our").

The SEE Portal is managed, maintained and technically supported by Earthware (https://www.earthware.co.uk), a UK-based service provider, acting for and on behalf of Santen as data processor.

The SEE Portal is intended for Healthcare Professionals only ("you", "your" or "users"); the SEE Portal is a medical education online platform dedicated to support your professional development about ophthalmology and tailored to your learning preferences, giving you access to articles, videos on demand and details of upcoming events, as well as information and materials on Santen products and services, as further described below.

At Santen, we recognize the importance of, and are fully committed to protecting the privacy of personal data related to all individuals with whom we interact. This Policy is designed to assist you in making informed decisions when using our website or interacting with us.

You are recommended to read carefully this Policy before disclosing any personal data and/or filling in any electronic form posted on this website. By visiting our website or by providing us your personal data, you agree and consent to the collection, use and disclosure of your personal information as outlined in this Policy.

Scope of this policy

This Policy is specifically intended for healthcare professionals interested in using the SEE Portal to access medical education resources relevant to eye disease.

Personal data we collect

When you use the SEE Portal, we may collect and process the following personal data:

(a) Personal Data directly provided by you and processed by Santen and its data processor, Earthware, on the SEE Portal:

(b) Personal Data collected and processed by IQVIA/OneKey Web Authentication Service:

(c) Personal Data collected automatically

Personal data related to you may be also collected automatically by your use of our website or whenever you choose to disclose it by updating your User Profile information, completing our Contact us online form or whenever you choose to send us directly an email at the designated email addresses.

Such data, indirectly collected, include but is not limited to the following:

Digital usage data generated automatically from your use of our SEE portal or from the delivery/use of services and/or content from the SEE portal, such as login user credentials, time and date of login, IP address, your browser type and version, time zone setting, content request, status of access/Http status code, transferred volume of data, website requesting access, time period of user's staying on a single page, the internal path analysis and/or other parameters regarding the user's operating system and computer environment, browser plug-in types and versions, operating system and platform and other data transmitted via Cookies, web beacons (also known as "tracking pixels", which are typically used, for example, to count the number of visitors to the website, to monitor how users navigate the website and to count content views), embedded scripts, location-identifying technologies, device recognition technologies, and other tracking technologies ("Tracking Technologies"). This data is collected and used in most cases in an aggregated and not immediately identifiable manner, such as for security management purposes, to ascertain responsibility in case of possible crimes against the site (e.g. cyberattacks, DDoS attacks) or upon public authorities' request. Subject to the user's consent, this data can be collected at an identifiable user/customer level to personalize the user's experience, as further explained in our Cookies Policy.

User activity tracking data: In addition, we will collect certain types of activity tracking data, which includes data that reveals how you interact with the SEE portal and applications as well as with our electronic communications (e.g. via email, SMS, or other digital apps) and advertisements; such data will be linked to your educational - professional preferences such as what presentations, course modules and other content in the platform that you open and finish, as well as the amount of time you spend actively working on a presentations, course modules, seminars or the like, group and other invitations that we send you. We collect this data to gain insights on which kinds of activity and content are most frequently accessed and used by our users; such data collection enables Santen to review and evaluate the performance of the digital media we make available and the relevance of the content we provide to our users and allows us to adjust our sending habits and our digital communication campaigns to best suit the needs of the intended recipient and/or audience as well as to optimize the relevant content leading to a tailored user/customer experience. Santen may collect such data in an aggregated and not immediately identifiable manner, or at an identifiable user/customer level, subject to the user's/customer's consent.

Purpose of processing personal data

Santen will collect, store and otherwise process your personal data to provide the SEE Portal services to you or for purposes permitted by applicable laws, including the Swiss Federal Act on Data Protection 1992, as amended and in force, and on the terms set forth in this Policy. By registering for and using the SEE Portal you give your express permission to Santen to process your personal data for the purpose of delivering the SEE Portal services to you and for other compatible purposes as further described below:

Santen will process personal data for further purposes, where lawful to do so (such as for scientific or market research as well as for archiving or statistical purposes) or when legally obliged to do so (such as to comply with our safety reporting obligations). We retain your personal information as long as it is necessary for the aforementioned purposes or as required by applicable laws. When such requirements no longer exist, your personal information will be deleted or rendered completely anonymous.

Legal basis of processing

Santen processes personal data based on one or more of the following conditions:

Cookies

Cookies are small files that the website places on your hard drive for identification purposes. Cookies can be "persistent" or "session", "first-party" or "third-party" cookies. This website uses "cookies," to analyse the use of our website and to give you the best possible user experience. Your web browser may allow you to be notified when you are receiving a cookie, giving you the choice to accept it or not.

For general information about our use of cookies please visit Santen S.A.- Switzerland Cookies policy here: https://www.santen.eu/data-privacy/cookies-policy; general information on cookies can also be found here www.aboutcookies.org, www.allaboutcookies.org.

The cookies that are strictly necessary for the correct functioning of this website are always activated and do not require your consent.

Other cookies are still reasonably necessary or important, but they are not strictly essential and, therefore, require your consent. For these cookies (i.e. Performance cookies), we request your consent (by the "accept all cookies" button in our cookie banner or through our cookies settings or your browser cookie settings) before placing them on your device.

If you do not wish to give consent or wish to withdraw your consent to any non-essential cookies at any time, you will need to modify your preferences in the cookies settings or delete, and block or disable cookies via your browser settings. This may, however, lead to a restriction of the functions or have adverse effects on the user-friendliness of our website.

When operating this website, we use the following categories of cookies:

  1. Strictly necessary cookies which are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
  2. Performance cookies which collect information about how visitors use a website, for instance which pages visitors go to most often, length of time spent on the site, and if they get error messages from web pages. These cookies do not collect information that identifies you. All the information that these cookies collect is anonymous and is only used to improve how a website works.
  3. Third party cookies

Some of our webpages use third-party services or software, such as online videos and images. These services may set cookies on your device. Third party services used by this website include:

Google Analytics: This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. For more details on Google Analytics and on how Google processes your data, please visit Google's Privacy policy

hCaptcha: This website uses hCaptcha to prevent bots from submitting forms on our site. As this is a key part of data submission on our site, we class this as a strictly necessary cookie and removing it would impact this function. You can find further details through hCaptcha's privacy policy here (https://www.hcaptcha.com/privacy).

The following table contains a detailed description of the cookies we use:

Cookie name Cookie Category Source Expiry Default status
_ga Analytics
Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
Google Analytics 2 years OFF / User Consent Required
consentPanel Necessary
This cookie is used to remember a user's choice about cookies on SEE Portal. Where users have previously indicated a preference, that user's preference will be stored in this cookie.
SEE Portal 24 years Always On

Data concerning website users will not be stored for a longer period than the above mentioned for each cookie type except for any need of checking computer crimes damaging the website in compliance with applicable laws.

Moreover, no information coming from the web service will ever be either communicated or disseminated to unspecified recipients.

Redirect to other web sites

From the SEE Portal, you can connect through special links to other websites of third parties to access content that has been created or endorsed by Santen. Santen assumes no responsibility regarding the processing activities of personal data or any activity by or content on third-party sites to which our website provides links. We encourage you to read and be aware of the privacy policy, and all other policies, of each site you visit. Remember, the statements in this Policy apply solely to information collected by Santen.

Disclosure of personal data

Personal data are not disseminated to unspecified recipients. Santen discloses your personal data to third party recipients on a need-to-know basis where this is reasonably permitted to pursue its legitimate business aims and as required by applicable law (i.e. disclosure of your personal data to IT and web hosting service providers).

For more information on Santen's privacy practices, how we handle your personal data and the measures we take in order to disclose it lawfully and safely internally and externally with our affiliates, service providers and partners, please read our Santen Privacy Policy available on our corporate website here: https://www.santen.eu/data-privacy

Automated decision making

Santen may combine any personal data you provide or any other information and insights automatically collected via the SEE Portal or via other digital media and online resources as well as information provided to us by third parties, to create a profile of our customers and business partners, to enable Santen to better manage our customer or business relationship with you; in particular, to facilitate Santen's decision making with respect to the various medical and/or scientific engagements and collaborations with the healthcare community; to optimize our digital media medical or scientific activities and to better understand the relevance of the content provided to our users/customers and partners; to allow Santen to offer our users/customers an experience tailored to their needs and preferences.

Santen will not make any automated decisions about you that would affect your legal rights or similarly affect you as an individual or negatively affect your business or customer relationship with Santen.

You can always raise any concerns you may have in relation to our decision-making and processing at any time by contacting us at privacy-emea@santen.com

Santen Email News & Updates

Subject to your express permission, Santen S.A. Switzerland and its local affiliates (collectively "Santen") would like to process and further use any personal information you provide directly to Santen during your user registration to the SEE portal, which forms part of your user profile (user account), including any identified preferences, as well as any information relevant to your use of the SEE portal, indirectly collected via Cookies and other tracking technologies, to send you electronic (email) communications on medical education, product information and other promotional activities relating to Ophthalmology and/or Santen, tailored to your areas of interest and expertise and your SEE portal online user activity, to offer your further learning, scientific and/or promotional opportunities as well as to enhance your customer profile and ongoing business relationship with Santen.

Providing your consent to such processing and further use of your personal information and related user activity is completely optional and does not have any effect on your registration and/or use of the SEE portal services. If you choose to provide your consent for the aforementioned purposes, you will still be able to withdraw it at any given time, without providing any reasons, by simply sending us an email at unsubscribe@santen.com

Your data protection rights

Under applicable laws and subject to any legal restrictions, you may have the right to request us to:

All data protection related requests should be addressed to Santen EMEA Privacy Office at privacy-emea@santen.com.

If we do not handle your request in a timely manner, or if you are not satisfied with our response to any exercise of these rights, you are entitled to lodge a complaint with the competent supervisory authority of your place of residence or work. Further information and contact details of the competent European supervisory authorities can be found here.

Policy updating

Santen reserves the right to amend this Policy from time to time to reflect technological advancements, legal and regulatory changes, and Santen's business practices, subject to applicable laws. If Santen changes its privacy practices, an updated version of this Policy will reflect those changes by posting any revisions on with the respective update of the effective date listed on the bottom of this Policy. We therefore encourage you to periodically visit this page to stay informed of how we are using your personal data.

Contact information

If you have any questions in relation to this Policy, or you want to obtain more information about Santen's privacy practices, please contact our Santen EMEA Privacy Office by email at privacy-emea@santen.com.

Last updated: 04 June 2024