Last upadated: Marth.30, 2023
Beijing InnoCare Pharma Tech Co., Ltd. and/or subsidiary ) ( “InnoCare”, “we”, “us”, “our”) honors its trusted relationships with employees, study participants, healthcare professionals, and business partners by being transparent about how we collect, use, share, transfer, and retain personal information. We encourage you to explore this webpage, and the webpages and notices to which it links, in order to learn more about our privacy practices.
Our websites may contain links to third-party websites that we do not operate, control or endorse. Once you leave our websites, we are not responsible for the protection and privacy of any information you provide. We suggest reading the privacy policies of these third-party websites and if needed, contacting those websites directly for information about their privacy practices.
We do not sell personal information and have not done so ever.
This Privacy Policy is directed at:
visitors and users of InnoCare’s websites, products and services, individuals within our former, current and prospective clients, partners, vendors, consultants, contractors, service providers, job candidates and any members of the general public who communicate with us, who provide InnoCare with personal information and/or whose personal information we receive.
If you are a participant in a InnoCare sponsored clinical trial or other non-clinical study, please see the copy of the Informed Consent Form that you received to understand the applied privacy policy.
This Privacy Policy contains specific sections that may not be applicable to you, please choose the applied sections in accordance with the category of your interaction with InnoCare.
WHAT PERSONAL INFORMATION ABOUT ME IS COLLECTED AND HOW IS IT USED, RETAINED, SHARED AND TRANSFERRED?
● When do we collect your personal information:
✧ We take or require appropriate technical, physical, and organisational measures to protect your personal information from misuse or unauthorized alteration, loss, or access;
✧ We collect and use your personal information only for the purpose(s)listed in this Privacy Policy or we informed you from time to time;
✧ We will collect your personal information to the minimum extent necessary serving the purposes.
Certain information (such as, your payment-related information, government-issued identification, geolocation information, health, biometric and genetic information) may be considered sensitive personal information under applicable laws. We will:
✧ take appropriate measures to protect and process your sensitive personal information; and
✧ provide notices and/or obtain your explicit consent for processing your sensitive personal information where required by applicable laws.
● Why do we collect your personal information:
● Where is your personal information used or stored?
We may share, transfer or store your personal information outside the jurisdiction of your place of residence.
Your personal information may be transferred when we make sure that the integrity and security of the information are adequately protected or that appropriate measures are adopted for complying with the applicable laws about privacy and data protection. We will take all reasonable measures and maintain appropriate physical, technical, organizational and administrative security measures to help protect your personal information from accidental or unauthorized access, disclosure, deletion, loss, use, alteration, destruction and processing.
● How long is your personal information used and stored?
We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the personal information concerned.
We will store and use your personal information for as long as is reasonably necessary for conducting the research study or other appropriate purposes, and for a reasonable period of time thereafter in order to comply with applicable laws regarding the conduct of InnoCare.
● What are your rights?
You have a number of rights which apply to our use of your personal information. The availability of some of these rights depends upon our lawful basis for processing your personal information and your rights may also be subject to certain conditions and restrictions. You may have the right as follows:
✧ to access to your personal information together with information about how and on what basis that personal information is processed;
✧ to rectify inaccurate personal information (including the right to have incomplete personal information completed);
✧ to erase your personal information in limited circumstances where it is no longer necessary in relation to the purposes for which it was collected or processed;
✧ to change your consent for processing where the legal basis relied on is consent;
✧ to obtain more information as to safeguards under which your personal information is transferred outside of China (if relevant); or,
✧ to lodge a complaint with the data protection noted below.
✧ We may ask you for additional information to confirm your identity for security purposes, before disclosing the personal information requested to you.
✧ Certain information, such as (if applicable) your payment-related information, government-issued identification, geolocation information, health, biometric and genetic information, may be considered sensitive personal information under applicable laws. We will:
✧ take appropriate measures to protect and process your sensitive personal information; and
✧ provide notices and/or obtain your explicit consent for processing your sensitive personal information where required by applicable laws.
● Who can you contact regarding your rights?
Data Controller:The entity that determines why and how your personal information is processed is called Data Controller.
✧ For recruiting activities, Data Controller is the InnoCare entity to which you are submitting your application.
✧ For healthcare professionals (HCP), institutional or pharmacy business contacts, Data Controller for the processing of your personal information is the InnoCare organization entity that sponsors the above personnel to act as investigators, to participate in scientific/medical conferences or report safety information.
✧ For others, Date Controller for the processing of the personal information is the InnoCare eneity listed below, depending on our relationship with you.
• Building Visitors: the InnoCare entity that you visit;
• Contractors/Non‐HCP Consultants: the InnoCare entity who you or your employer have a contract with;
• Third‐Party/Vendor/Business Partner Employees: the InnoCare entity who you work with.
Following are our targeted privacy notices related to the identity：
JOB CANDIDATES
HEALTHCARE PROFESSIONALS (HCP), RESEARCH INVESTIGATORS & RESEARCH STAFF, ADVERSE EVENT/SPECIAL SITUATION/PRODUCT COMPLAINT REPORTERS AND INSTITUTIONAL OR PHARMACY BUSINESS CONTACTS
OTHERS
PRIVACY ABOUT CHILDREN
JOB CANDIDATES
What personal information do we collect and use?
1. Candidates
✧ We collect and use the following personal information:
• Your Personal Details – for example your name, nationality, second nationality, personal contact details (e.g. home address, telephone number, e‐mail), and current role;
• Qualifications – education (certificates, diplomas, degrees), professional experience, languages spoken, competencies, and skills;
• Immigration or right to work status – legal ability to work within a certain location;
• Assessment data – for example interview notes or test results;
• Vetting and verification information – for example references;
• Any other personal information which you choose to disclose to InnoCare personnel during the application or interview process, whether verbally or in written form, including in particular any other information which you disclose on a CV / resume; and,
• Informal information including opinion information generated during the application or interview process.
✧ We collect this personal information in order to:
• Assess your suitability and aptitude for potential employment with us;
• Set up and conduct interviews and tests; and
• Select an applicant to hire.
✧ We process your personal information in order to enter into an employment contract with you if you are the successful candidate.
✧ We will also process your personal information if you consent to us keeping it for longer if your application isn’t successful but you want us to automatically consider you for other jobs that will become available in the future. We will only keep it for as long as the law tells us we can.
2. Successful Applicants
✧ We collect and use the following personal information but only as necessary, permitted, or required under local law:
• Your Personal Details – date of birth, gender;
• Immigration or right to work data – national ID number, social security or national insurance number, visa or work permit;
• Vetting and verification information – birth certificate, driver’s license, background checks(including of publicly available information and public social media profiles); and,
• criminal record disclosure.
✧ We collect this personal information in order to:
• Review your eligibility to work;
• Deal with the tax and social security matters (personal number);
• Seek criminal record disclosure (where permitted by local law); and
• Enter into a contractual relationship for employment with you.
✧ We process your personal information in order to enter into an employment contract with you and provide you with benefits, etc. We explain more about how your personal information will be used as an employee when we work with you to onboard you into the company.
Sources of personal information
You provide most of the personal information we process when you fill out an application on our recruitment website, but we sometimes get some of your personal information from a recruitment agency, cooptation, professional social network, a current employee as a referral, or by corresponding with you directly by post or email. During the recruitment process, we may also request references from third parties, for example references provided by you, and we may also carry out screening and vetting processes using third party sources who can tell us if you are eligible to work for us.
Who do we share your personal information with?
Your personal information is shared by InnoCare with:
✧InnoCare entities, wherever located in order to make decisions about your application or, if you provided consent, for future applications. Within InnoCare, your personal information can be accessed by or may be disclosed internally on a need‐to‐know basis to the hiring manager and any other relevant business colleagues responsible for managing or making decisions in connection with your potential employment with InnoCare.
✧Third parties that help support our recruitment and, for successful applicants, our hiring and onboarding activities. These third parties may have access to or merely host your personal information or support and maintain the framework of our recruitment system. InnoCare expects these third parties to process any personal information disclosed to them in accordance with applicable law, including with respect to information confidentiality and security. This processing on InnoCare’s behalf will also be conducted as outlined in contractual obligations between InnoCare and its service provider.
✧Third parties, such as government agencies, regulators, or public authorities, but only when they require us to.
HEALTHCARE PROFESSIONALS (HCP), RESEARCH INVESTIGATORS & RESEARCH STAFF, ADVERSE EVENT/SPECIAL SITUATION/PRODUCT COMPLAINT REPORTERS AND INSTITUTIONAL OR PHARMACY BUSINESS CONTACTS
What personal information do we collect and use and how long is it stored?
1. Healthcare Professional Business Contacts
✧ We collect and use the following personal information:
• Your name, business contact details, and professional qualifications(sources: public sources such as websites or third party data providers, or directly from you or your employer);
• Information specific to our professional interactions, e.g. meeting visit notes, (source: directly from you);
• The scheduling of meetings with you (source: directly from you or from your employer or place of business);
• Information relevant to your professional interests such as promotional, medical, and educational information (source: directly from you or from a third party provider); and
• Your potential or actual involvement in our clinical development programs (source: directly from you; our clinical research records; or public sources such as scientific and medical publications, national registries, and the Internet).
✧ We collect this personal information in order to:
• Schedule meetings with you;
• Determine your interest in receiving information relating to InnoCare products;
• Provide Information relevant to your professional interests such as promotional, medical and educational information;
• Initiate or follow‐up for clinical development programs;
• Administer or follow up for the supply of medicinal product(s) based on your unsolicited request (e.g.: compassionate use and/or early access program pre‐authorized by competent bodies and/or authorities); and
• Comply with voluntary or regulatory transparency reporting disclosures or other regulatory obligations.
✧ We collect and use this personal information as necessary based on our legitimate interest or based on your opt‐in or consent. Where applicable, we also collect and use this personal information as necessary based on our regulatory transparency reporting or other regulatory requirements.
2. Research Investigators & Research Staff
✧ We collect and use the following information:
• Your name, business contact details, professional qualifications and interests, (source: third party data provider or directly from you or your employer);
• Information specific to our professional interactions, e.g., meeting visit notes), (source: directly from you); and,
• The scheduling of meetings with you, (source: directly from you).
✧ We collect this personal information in order to:
• Coordinate your involvement in an InnoCare sponsored research in order to contact you, contract with you, provide you with information about the research, and schedule meetings and appointments with you;
• Comply with InnoCare’s legal obligations in its conduct of research; and,
• Comply with voluntary or regulatory transparency reporting disclosures where applicable.
✧ We collect and use your personal information (1) as necessary based our legitimate interest; (2) based on InnoCare’s legal obligations under applicable laws; (3) in performance of a contract with InnoCare; and/or (4) based on your consent.
3. Adverse Event/Special Situation/Product Complaint Reporters
✧ We collect and use the following personal information:
• Your name, business contact details, credentials, and employer (source: directly from you or one of your patients or patients’ caregiver).
✧ We collect this personal information in order to:
• Understand the safety and efficacy of InnoCare’s study drugs or products in the market; and
• Comply with InnoCare’s legal obligations in the conduct of research, access programs or an unlicensed product, or manufacturing and distribution of a marketed product for reporting safety and product complaints.
✧ We collect and use this personal information based on InnoCare’s legal obligations under applicable laws.
4.Business Contacts at Institutions or Pharmacies
✧ We collect and use the following personal information:
• Your name and business contact details (source: third party data provider or directly from you); and
• Information specific to our professional interactions such as meetings and meeting notes(source: directly from you).
✧ We collect and use your personal information (1) in performance of a contract with InnoCare; (2) based on InnoCare’s legal obligations under applicable laws; and (3) for legal proceedings, investigations and questions from competent authorities.
Who do we share your personal information with?
✧ With your consent, your personal information is shared by InnoCare with:
• Third party consultants, service providers, partner companies contracted by or on behalf of InnoCare , wherever located;
• Healthcare professional boards, authorities, wherever located;
• Government agencies, regulators, or public authorities, but only when they require us to. In some instances, these government agencies may make your personal information public in accordance with applicable laws or guidelines;
✧ Where required by institutional policy or government entity, to your employer.
OTHERS
What personal information do we collect and use and why?
With your consent, we collect and use the following personal information:
1.Building Visitors
✧ Contact Information: Your name, email address, and telephone numbers, signature;
✧ Your job title and employer (if applicable to your visit);
✧ A standard photo of you for access purposes (if required);
✧ Records of surveillance cameras, if applicable and as per local legislation; and
✧ Your fingerprints in order when you access an InnoCare building with this capability, if applicable and as per local legislation.
✧ We collect and use this personal information directly from you or in our systems during the course of your visit, to the extent necessary for the pursuit of InnoCare’s legitimate interests to manage business operations and for the security of its property, reputation, customers, employees, and third parties.
2.Contractors/Non‐HCP Consultants
✧ During Your Work for InnoCare
• Contact Information: Your name, professional email address, professional email address and telephone number, and personal email address and telephone number (as applicable);
• Payment and/or bank details (for those with direct contracts with InnoCare)；
• Job/position: Contract title and description; InnoCare contracting entity name; branch/unit/department; Job location; status and type of contract (full time/part time); actual hours worked for InnoCare, start and termination dates, hourly rate, and employer/agency;
• Meetings attended; recordings of those meetings (in compliance with image and voice rights); and materials presented or used;
• Department specific, corporate, and compliance trainings attended and related certificates;
• Department specific, corporate, and compliance policies and procedures read;
• Video or photographs of you in a larger group of employees and contractors as part of corporate projects and company activities such as an annual yearbook or company event;
• IT System identifiers: System‐ID; LAN–ID; system‐passwords; software‐ or other licenses; and
• device identifiers for devices provided by InnoCare;
• Log details internal databases and drives;
• Emails and email content created by or received by you where such emails contain your personal information;
• Instant messages created by or received by you where such messages contain your personal information;
• Records of electronic content created by or accessed by you using InnoCare systems and InnoCare‐owned devices;
• Monitoring records of general activity in systems including downloads to USB and uploads to cloud storage services to prevent loss of and unauthorized access to data;
• A standard photo of you for access card purposes;
• Records of surveillance cameras, if applicable and as per local legislation;
• Your fingerprints in order when you access an InnoCare building with this capability, if applicable and as per local legislation; and
• Use of your access card to InnoCare premises.
✧ We collect and use this personal information directly from you, your employer, or in our systems during the course of your work for InnoCare, to the extent necessary for the pursuit of InnoCare’s legitimate interests to manage business operations and for the security of its property, reputation, customers, employees, and third parties.
If you are under contract directly with InnoCare, we collect and use the personal information provided by you (1) in performance of a contract with InnoCare; and (2) for legal proceedings, investigations, and questions from competent authorities relating to our contract with you.
✧ When You Give Your Consent
• From time to time we may ask for your consent to collect certain personal information from you. You will receive more detailed information on what we want your consent to collect and what it will be used for at that time. In cases where we explicitly rely on your consent or where we mark the provision of information as optional you are not obliged to provide us with the information and in not doing so, your contracted role with InnoCare will not be placed in jeopardy.
3.Third‐Party/Vendor/Business Partner Employees
✧ Contact Information: first name; last name; professional address; professional e‐mail address; professional telephone numbers;
✧ Job title and description and employer;
✧ Information specific to our professional interactions such as meetings, meeting notes, and audio or visual recordings;
✧ SystemIdentifiers:System‐ID;LAN–ID;system‐passwords;software‐orotherlicenses;and device identifiers for any devices provided to you by InnoCare;
✧ Log details of internal databases and drives for access provided to you by InnoCare;
✧ Emails and email content sent to you from InnoCare or sent by you to InnoCare where such emails contain your personal information;
✧ Instant messages sent to InnoCare by you where such messages contain your personal information;
✧ Records of electronic content created by or accessed by you (if accessed) using InnoCare systems and InnoCare‐owned devices;
✧ Monitoring records of general activity in InnoCare systems (if accessed) including downloads to USB and uploads to cloud storage services to prevent loss of and unauthorized access to data;
✧ We collect and use this personal information directly from you, your employer, or in our systems during the course of your interactions with InnoCare, to the extent necessary for the pursuit of InnoCare’s legitimate interests to manage business operations and for the security of its property, reputation, customers, employees, and third parties.
✧ From time to time we may ask for your consent to collect certain additional personal information from you or wish that we may use your personal information for other purposes. In this case, we will seek your prior consent. You will receive more detailed information on what we want your consent to collect and what it will be used for at that time.
Who do we share your personal information with?
The same to the similar section of “HEALTHCARE PROFESSIONALS (HCP) AND INSTITUTIONAL OR CY BUSINESS CONTACTS” chapter.
PRIVACY ABOUT CHILDREN
Our Website is not directed at children under the age of 14 or equivalent minimum age in the relevant jurisdiction. We do not knowingly collect any personally identifiable information from any persons under such age.
COOKIE POLICY
In operating our websites, we gather and store certain information about you and your preferences—mostly to make our websites work the way you expect them to. We do this through the use of cookies placed on the device you use to visit our websites.
Cookies are pieces of information sent by a web server to a user’s browser. Cookies may include information such as user preferences, time spent on a website and pages visited. We use the information to identify you and to customize and improve your experience on the Website.
You may withdraw your consent to the use of any cookies (except for strictly necessary cookies) directly at any time by going to the Cookie Settings for respective InnoCare website. Withdrawing your consent does not affect the legality of processing carried out previously. Your refusal or the withdrawal of your consent does not prevent you from using the websites.
THIRD PARTY LINKS
This Privacy Policy does not apply to any other websites or platforms unless the context otherwise specifies. Please note that the Website may include links to other websites, platforms or products which are subject to privacy policies and practices that differ from ours. Such links are provided for your convenience and information only, and do not represent our affiliation, sponsorship, or endorsement of the information on third party sites. We are not responsible for the collection and processing of your information if you provide your information to any of those third parties or interact with such third-party websites.
OTHER STATEMENT
If you provide your personal information when using our website or interacting with us, you are deemed to have accepted the terms of Privacy Policy made by InnoCare. If you do not agree to any such terms, you may terminate the disclosure of your personal information to InnoCare (including but not limited on our websites) on your own initiative.
Insofar as it does not violate the law or infringe upon your legal rights, InnoCare reserves all rights to modify the relevant terms of use at any time. We will notify you of any material changes through a notification on the Website, and such change will only apply to information collected after the revised Privacy Policy takes effect. Any changes to this Privacy Policy will become effective immediately after being posted. We encourage you to periodically review this Privacy Policy to stay informed of changes and on how we are protecting your personal information.
HOW CAN I EXERCISE MY PRIVACY RIGHTS?
Depending on where you live or work, you may have certain rights regarding your personal information under applicable privacy and data protection laws. If you wish to exercise your rights, or if you have any questions about this Privacy Policy or the operation of this Website, or if you have any concerns about our use of your personal information, you may contact Legal and Compliance Department verbally or in written form (including email) or by oral, and we will try our best to respond as soon as possible.
HOW CAN I CONTACT INNOCARE?
If you have any questions about our privacy notices or practices, you may contact us at:
dataprivacy@innocarepharma.com
