Privacy Policy
1. Purpose and scope of the Privacy Policy
Bristol Myers Squibb spol. s r.o., a limited liability company with its registered seat at Budějovická 778/3, Michle, 140 00 Praha 4, company ID: 43004351, registered in the Commercial Register maintained by the Municipal Court in Prague, File No.: C 4801 (“Bristol Myers Squibb”, “BMS”, “we” or “us”) respects your interests and your rights with respect to data protection in adherence to applicable data protection law, especially the EU General Data Protection Regulation (GDPR), and values the relationship with you. This Privacy Policy applies to the website https://www.bmsstudyconnect.com/cz (“website”), operated by Bristol Myers Squibb. Websites directly or indirectly linked to our website (e.g. via hyperlinks), especially websites of other companies of the Bristol Myers Squibb Group, do not fall under the scope of this Privacy Policy. This Privacy Policy describes the collection and further processing of your personal data when you visit and/or you interact with us on the website, and describes the use of cookies on the website. In addition, this Privacy Policy contains other important information on the protection of your data, especially your legal rights with respect to your data and how you can reach us so we can answer any questions you might have about our data protection practice.
This Privacy Policy applies in supplementation to the Legal Notice, the Pharmacovigilance Notice and the Cookie Policy. In case of a conflict between this Privacy Policy and the Legal Notice and/or the Pharmacovigilance Notice and/or the Cookie Policy, the former shall prevail. Please read this Privacy Policy carefully. Should you disagree with any conditions included therein, please do not access the website and/or do not transmit the respective personal data to us.
2. How is the term “personal data” defined in this Privacy Policy?
“Personal data” are all information that refers to an identified or identifiable natural person (“data”), for example your name, date of birth, your address and e-mail address. We will only use your personal data in accordance with this Privacy Policy and will ask for your consent insofar as this is required by applicable law.
Any personal data you provide to us through the website is provided voluntarily (you have no obligation to provide the personal data). If you do not provided your personal data to us, you will not be able to use of or participate at certain functions or services available on the website.
3. Data we collect and how we use it
a. Personal data that we collect directly from you
In some areas of this website we collect data from you directly by asking you to provide the data, so we can respond to your request or give you access to specific areas/content/features. You will always have the option to refuse the provision of the requested information, but in this case you might not receive access to specific contents, sections or functions.
We explain below which data we collect from you directly and explain for which purpose and on what basis we process these data for you.
Contact
If you communicate with us via the “contact” link on our websites, we may request data from you such name, telephone number, professional information, e-mail address. We process the data you provide only to address and respond to your requests. The legal basis for processing of your personal data is our legitimate interest which consists in needs of BMS to communicate with you.
Screening questionnaires
On our website, we have questionnaires for you about your health condition and treatments, in order to see whether Bristol Myers Squibb clinical trials are an option for you. If your answers are a potential match with a clinical trial, you may have the option of signing up and sending your completed questionnaire to the clinical trial site where it will be reviewed and any further action will be taken.
BMS and its contractual partners can save and use your answers; however, these answers are not associated with your personal information or your Study Connect Account (if you have one), until you decide to register/sign up in order to send your data to a clinical trial site. When completing a questionnaire, you have to enter your year of birth, gender, medical history or health conditions information.
The legal basis for processing of your personal data is your consent.
Other use of data
We have the right to use the personal data you provide on the website for internal purposes. These purposes include the administration of the website, data analysis, as well as the adherence to our legal obligations, guidelines and procedures.
The legal basis for processing of your personal data is our legitimate interest or fulfilment of our legal obligations.
b. Automatically collected data personal data
We collect certain information automatically about how you use the website by placing and reading cookies on your device. For detailed information on the use of cookies on our website, see the Cookie Policy.
4. Exchange of data
We will not sell, lease or trade the information submitted by users of our website, nor will we disclose these data in any way, with the exception of the procedures described in this Privacy Policy. Personal data will be treated confidentially and in accordance with applicable law at all times.
If necessary for purposes of operating the website, its specific functions or certain services provided on the website, BMS will pass on your personal data to its parent company, Bristol Myers Squibb Company, 345 Park Avenue NY 10154, USA (“BMS USA”), a subsidiary of BMS USA and a service provider for the above-mentioned purposes (jointly referred to as “data receiver”). The service providers are in one of the following categories: IT (Application Support and Maintenance; Software Infrastructure) and are based in the USA and India. Some data receivers are located in countries outside the European Union or the European Economic Area (“third countries” without an adequate data protection level). In the case of these data receivers, BMS has taken appropriate action to ensure that your personal data that is transmitted is adequately protected, e.g. by EU standard contractual clauses or BMS binding corporate rules for personal data transfer within the BMS group. You have the option of receiving a copy of these documents by contacting eudpo@bms.com.
Furthermore, we disclose your data, if necessary, to government agencies and other third parties (i) if we are obligated to do so by law or by court decree, (ii) in response to an inquiry from a law enforcement agency or another government representative, or (iii) if we are of the opinion that the disclosure is necessary or appropriate in order to avoid personal or financial damages, or in connection with an investigation regarding suspected or actual illegal activity.
5. Duration of storage of your data
Please note that Bristol Myers Squibb automatically deletes your data one year after you grant your consent or agree to the saving and using of your information by Bristol Myers Squibb and the parties that BMS works with in order to provide notices and associated services to you.
Please note that data sent to a clinic/practice at your request (questionnaire and registration feature) are subject to the privacy policy of the clinic/practice. You need to request the deletion of your data at a clinic/practice there directly.
The data collected in accordance with paragraph 3) a) by means of the contact form is stored by us for a maximum of one year; after that, your data are deleted.
For information about the storage duration of the data collected under paragraph 3) b) please see the Cookie Policy.
6. Links to other websites
Occasionally, we will provide links to other websites for your convenience and information. These websites are operated independently from our website and are not subject to our control. The respective websites may be subject to different privacy policies or conditions of use, so that we must urge you to read these carefully prior to visiting any linked websites. We are not liable for the contents of these websites, for any products or services offered on these websites, or for any use of the linked websites. For further information on this topic, please read the Legal Notice.
7. Protection of personal data
We maintain administrative, technical and physical protective measures for the website that, in accordance with applicable law, are meant to offer protection against the loss, the misuse or unauthorized access, disclosure, the modification or deletion of the personal data we collect on the website.
8. Change of the Privacy Policy
To the extent permitted by applicable law, Bristol Myers Squibb has the right to modify the conditions of the Privacy Policy governing this website. Should any conditions of this Privacy Policy be modified, the modified Privacy Policy will be published on the website.
9. Your rights with respect to your data
In accordance with the legal provisions on data protection, you have the right at any time to:
· request to obtain the confirmation whether or not the your persona data are being processed, and if they are, the you have the right to access the personal data under the conditions set out in Art. 15 GDPR;
· correct incorrect data and to demand completion of incomplete data in consideration of the purposes of processing (right to rectification) under the conditions set out in Art. 16 GDPR;
· demand deletion of your data in case of legitimate reasons (right to erasure) under the conditions set out in Art. 17 GDPR (e.g. the processing is unlawful, we no longer need your data for the respective purposes, or you revoke your consent);
· demand the restriction of processing of your data, if the legal requirements set out in Art. 18 GDPR are met (e.g. you contest the accuracy of the data, the processing is unlawful or we no longer need your data for the respective purposes) (right to restriction of processing);
· if the legal requirements set out in Art. 20 GDPR are met, to receive your provided data in a structured, commonly used and machine-readable format and transmit those data to another controller or, if this is technically feasible, to have them transmitted by Bristol Myers Squibb (right to data portability); and
· not to be subject to a decision based solely on automated processing, if the legal requirements for this are met. Bristol Myers Squibb presently does not engage in automated decision-making in connection with your use of the website.
In addition, you have the right to object to the processing of your data for reasons arising from your particular situation in the cases provided for by law (right to object). However, you have this right only in cases where BMS processes your personal data based on a legitimate interest of BMS or third person. If you exercise this right, we will longer process your personal data unless we demonstrate compelling legitimate grounds for the processing or for the establishment, exercise or defence of legal claims.
In addition, you have the right to withdraw any consent given by you in connection with the registration or use of our services, but this will not affect the lawfulness of processing based on consent before its withdrawal.
Further, without prejudice to any other legal remedies, you have the right to lodge a complaint with a regulatory authority at any time. The regulatory authority in the Czech Republic is the Office for Protection of Personal Data (in Czech: Úřad pro ochranu osobních údajů). Up-to-date contact details are available at https://www.uoou.cz/.
To exercise your rights, please use the contact details below.
10. How you can contact us
If you have questions about the processing of your data in connection with the use of the website or would like to exercise your rights described above, you can contact our data protection officer at any time using the following contact information:
· by e-mail:
eudpo@bms.com
· by mail:
Bristol Myers Squibb spol. s r.o.
Budějovická 778/3, Michle
140 00 Praha 4
Czech Republic
The people who appear on this website are for illustration purposes only.
Unless stated otherwise, all depicted persons are models and not real patients.
