Santen Eyecare Education – SEE Portal – Privacy Policy

Our commitment to privacy

This website of Santen Eyecare Education (“SEE”) Portal https://santensee.eu (the "SEE Portal", “website” or "service") is operated by Santen S.A.- Switzerland. (Santen S.A.- Switzerland, Address: La Voie-Creuse 14 1202 Geneva Switzerland URL: www.santen.eu) ("Santen", “we”, “our”).

Upon your first visit on the Website you will be asked to select the country of your residence as well as to declare that you are a Health Care Professional (HCP). Then you will be redirected to the SEE Portal website of your country of residence where a dedicated privacy policy shall be applicable.

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 directly from you, including but not limited to:

Data processed by Santen and its data processor, Earthware on the SEE Portal:

• Identification information and contact details such as name, professional registration number, OneKey ID, address, email address and phone number;
• Professional data, such as your professional registration number, place of work, job role and specialisation;
• User credentials, such as your OneKey user id and OneKey verification status;
• Additional data you provide when you subscribe to SEE portal such as your communication preferences, language preference, areas of interest, your seminar, congress, webinar and similar registrations (including whether you decline an invitation), other information you may add in the platform (such as personal notes, messages, answers you provide to registration questions, and your feedback on the content we provide); activities/engagement with Santen (such as meetings with Santen representatives, attendance at meetings sponsored by Santen); and samples and promotional items provided;
• Digital data generated automatically from your use of our platform, such as 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, 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. This data is collected and used only in an aggregated and not immediately identifiable manner. Moreover, we will collect data 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.
• Other information such as communications and queries you make to Santen.

Personal Data processed by IQVIA/OneKey Web Authentication Service:

• Identification information and contact details such as name, title, date of birth, email address and phone number;
• Professional data, such as your profession, professional registration number, your organization/institution you are belonging to and your business address;
• User credentials, such as your username and password;

Personal data related to you may be 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.

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:

• For the establishment, management and organization of tailor-made high-quality eye disease medical education in accordance with the specific educational needs of each particular healthcare professional/ user.
• To manage our relationship, interactions and communications with you: for example, to respond to your questions and comments or inquiries, to invite you to events, webinars and other learning modules organized or sponsored by Santen and/or third parties.
• To managing your preferences: for example, providing your recommendations on training modules and events on your areas of interest.
• Marketing communications: to provide you with information relating to Santen product and services and inform you about other promotional activities in accordance with applicable laws. Such uses might include event management, provision of information and services that you have requested (such as information on Santen products), reports of healthcare professional visits and tailoring the seminar invitations we send you based on your interests. Please also note that we may use the personal information for the SEE Portal to send you from time-to-time email and other messages, e.g., in order to inform you of new group messages, new features, to remind you of seminar sign-ups and similar.
• Business relationship with Santen: Santen may also use your personal information for the development, tracking and profiling of scientific and medical activities and initiatives in which you are involved with Santen’s Medical Department. These may include clinical trials, medical education, scientific advisory boards and exchange of scientific information.
• Website functions: We will use your data to monitor the proper functioning of the platform, how it is used and for the purposes of developing it to ensure that content from our website is presented in the most effective manner for you and for your device.

Santen will process personal data for further purposes, where lawful to do so (such 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.

Legal basis of processing

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

• Where you have provided your consent, for example to handle and respond to a communication or a query you have submitted to Santen via the Contact Us form or for the deployment of optional cookies such as functional or performance cookies or to send you email push notifications at your request; in such cases, your consent can be withdrawn at any time and without giving any reason;
• Where the processing is necessary to ensure Santen’s compliance with a legal obligation e.g. for example when you report an adverse event to us;
• Where the processing is in Santen’s legitimate interest, for example where such processing is strictly necessary for the technical operation of the website or for the maintenance of our current or future business relationship with you.

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 use “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
ARRAffinity ARRAffinitySameSite	Necessary These are used by Microsoft Azure to hold state information whilst you are using the website. When you close the browser this session information is automatically removed. You are unable to opt out of using this cookie as it is required for the application to function. This cookie does not collect personal data.	Azure	Session	Always On
CookieConsent	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	1 month	Always On
INGRESSCOOKIE, _cfduid, _cflb, session, sessionid	Necessary SEE Portal uses hCAPTCHA anti-bot service on forms submission. These cookies are strictly necessary for technical purposes of load balancing and routing.	hCaptcha	Session (up to 30 days)	Always On
.AspNetCore.Cookies	Necessary SEE Portal uses forms authentication when you log in; this cookie is created and stored on your device to enable you to stay logged in. if this cookie is blocked you will not be able to log in to the site.	SEE Portal	Session	Always On
use-language	Necessary This cookie is used to remember any selection a user has made about language on SEE Portal, using the language selector, so that the site will be shown in their chosen language when returning to the site.	SEE Portal	Session	Always On
_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
_gat	Analytics Used by Google Analytics to analyse unique visitors to a website by assigning a random ID to each user and reporting on visits, sessions and conversions.	Google Analytics	1 minute	OFF / User Consent Required
_gid	Analytics Registers a unique ID that is used to generate statistical data on how the visitor uses the website.	Google Analytics	1 day	OFF / User Consent Required

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

Automated decision making as part of this educational information platform is limited solely to managing your profile preferences, your areas of interest and other provided details from you to facilitate your access and participation to the various events and learning modules. We will also analyse your use of the platform to tailor its contents to your interests and preferences and send you email notifications with related contents and updates subject to your express permission.

You have the right to object to such automated decision making by contacting us at privacy-emea@santen.com at any time.

Your data protection rights

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

• Provide you with further details on the processing of your personal information;
• Provide you access to your personal data that we hold about you;
• Rectify any inaccuracies in the personal information we hold that is demonstrated to be inaccurate or incomplete;
• Delete any personal information that we no longer have a lawful basis to use;
• Stop a particular processing when you withdraw your consent, at any time and free of charge;
• Object to any processing based on the legitimate interests or public interest to process information, unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights. and
• Restrict certain aspects of the processing of your information.

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

Last updated: November 22, 2021.