Engagements with Healthcare Professionals and Healthcare Organization (“HCPs”)
This Data Privacy Statement explains how MC2 process your personal data when you have an engagement with us.
1. USE OF PERSONAL DATA
We may use your personal data for the following purposes:
- To provide, collect, review, and communicate information on the proper use of drugs, medical devices, drug samples, and other goods and products handled by MC2 (hereinafter referred to collectively as “Medical Products”).
- To provide, collect, review and communicate information on quality, safety or effectiveness of Medical Products.
- To interact and collaborate with you based on your professional expertise when we have a contractual relationship with you.
- To provide, collect, review, and communicate healthcare-related information.
- To report on the occurrence of adverse effect, accident, recall of Medical Products.
- To check, review and take reasonable action to request for information and inquiry,
- To conduct research of delivery destinations, actual use, and user’s needs of Medical Products.
- To request and implement clinical trials, post marketing surveillance studies and other studies.
- To handle complaints about our products and services.
- To cultivate better communication among HCPs.
- To make notifications and reports to government and other public offices and agencies.
- To contact HCPs regarding the above tasks.
2. CATEGORIES OF PERSONAL DATA
We may collect the following personal data about you:
Name, address, email address, telephone number, employer, CV, title, occupation, affiliation, professional qualifications, and scientific activities (such as previous clinical trial experience, and participation in past or pending research studies with MC2 and other companies), transfer of value, professional license information and contract information including billing information.
We may collect your personal data from various sources such as:
- Documents or forms that you provide to participate in our sponsored or supported initiatives, such as sponsored clinical trials and development activities.
- Publicly available sources.
- Professional vendors.
- Your employer.
- Online and from databases and websites, which may be managed by third parties on our behalf.
4. LEGAL BASIS
We process your data on the following legal basis:
Art. 6 (1)(f) of the GDPR – Legitimate interest. This means that the processing of your personal data is necessary for the purposes of the legitimate interests pursued by us when assessing the activity/services and legitimate business need, adherence to local law and industry standards, and assessing fair market value.
Art. 6(1)(b) of the GDPR – Performance of Contract. If you have a working relationship with us such relationship is confirmed in writing and personal data will be collected to perform the contract.
Art. 6(1)(a) of the GDPR – Consent. In certain situations, we also ask for your consent to process your personal data, e.g., for disclosure of transfer of value, if such disclosure is not a legal obligation.
Art. 6(1)(c) of the GDPR – Legal Obligation. For clinical trials we may also process your personal data in relation to adverse event reporting to adhere to a legal obligation.
5. SHARING OF YOUR PERSONAL DATA
We may share your personal data with:
Our affiliates, collaborative partners, authorities, and other HCPs.
6. TRANSFERS TO COUNTRIES OUTSIDE THE EU/EEA
Your personal data may be transferred within the EEA or to countries outside the EEA, that are not deemed to provide an adequate level of protection of your personal data compared to the EEA. Instead, we have provided appropriate safeguards as required by GDPR art. 49 (1) through EU standard contractual clauses.
You may obtain a copy of the EU standard contractual clauses by contacting us on: DataPrivacy@mc2therapeutics.com
7. RETENTION OF YOUR PERSONAL DATA
We retain personal data where we have an ongoing legitimate business need to do so (e.g., to maintain our engagement with you).
When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it or, if this is not possible (e.g., because your personal data has been stored in back-up archives), we will securely store your personal data and isolate it from any further processing until deletion is possible.