Our commitment to privacy
This website (www.myeyecare.health) is operated by Santen UK Limited (“Santen”) to offer to our website visitors (“you”, “your” or “website users”) educational information about dry eye disease and over the counter treatments for dry eye disease. 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 – including patients, members of the public, healthcare professionals and business partners.
Individuals are recommended to read carefully this Policy before disclosing any personal data through any communications with Santen to request clarifications and/or more information relating to the available educational material published through 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 to provide information to our website users, members of the public who interact with Santen, patients that use Santen products.
Personal data we collect
We may collect and process the following personal data about you, including but not limited to:
- General data such as name, postal and/or email address, phone number, through the queries you make to Santen after visiting our website;
- Professional data, such as your business address, business email address, business phone numbers, job title/position following any communications that you might have with us where you express your interest in Santen’s activities, ;
- Digital data generated from your use of our website, such as IP address, your browser type and version, time zone setting, 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. This data is collected and used only in an aggregated and not immediately identifiable manner; they could be used among others to ascertain responsibility in case of hypothetical crimes against the site or upon public authorities’ request.
Ways of obtaining personal data
In most cases, Santen will collect data directly from you, although sometimes we will obtain data about you from public or third-party data sources, including but not limited to cases that Santen may collect data from your computer or any other devices you use when visiting Santen’s website, such as internet protocol (IP), domain name, internet service provider (ISP), data about date and time of your request and other information provided by tracking technologies (e.g. through Google Analytics). Please see our Cookies policy.
When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary for us to provide for example additional to the online information (e.g. email; telephone), we may not be able to provide you such information.
Purpose of processing personal data
Santen will process your personal data only for purposes permitted by applicable laws, including the UK Data Protection Act 2018 (DPA 2018), as amended and in force, and on the terms set forth in this Policy. The purposes of the data processing activities may include:
- Managing our relationships/communications with individuals: for example, responding to questions and comments or inquiries about our online educational material.
- Website functions: 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 or when legally obliged to do so.
Legal basis of processing
Santen processes personal data based on one or more of the following conditions:
- Where you have provided your consent (in which cases, such consent can be withdrawn at any time and without giving any reason);
- Where it is necessary to comply with contractual obligations with you; or
- Where the processing is in Santen’s legitimate interest.
Redirect to other web sites
Place of data processing and ways of transmission
Santen UK Limited is located in England. Santen also operates through affiliates in Japan and other countries around the world. Personal data about you may be accessible to Santen EMEA affiliates as well as, to the extent permitted by applicable data protection law, to Santen affiliates outside European Union (“EU”)/European Economic Area (“EEA”), and to selected vendors and partners, established in the UK, EU/EEA or globally.
Where Santen processes personal information in countries that may not provide the same level of data protection as in the in UK, Santen will implement reasonable and appropriate legal, technical and organisational security measures with the aim to ensure the security of the processing and in particular to protect your personal data from unauthorised access, use or disclosure.
In the absence of an adequacy decision adopted by the European Commission, Santen will implement appropriate data transfer mechanisms (such as the EU Standard Contractual Clauses (SCCs)) for any cross border data transfers from UK to an affiliate or a third party (controller or processor) located in a non-EU/EEA third country with the aim to secure such transfers and achieve an adequate level of data protection.
Contractual arrangements with third parties and international data transfers
As a data controller, Santen aims to establish a high level of data protection and privacy for its data subjects and partners alike. To that end, Santen has developed and uses specific privacy and security related language in its contractual arrangements with third party service providers acting for the benefit of Santen as data processors in compliance with applicable data protection legislation.
Through its privacy-compliant contractual arrangements, Santen sets out the scope, subject-matter, duration and purpose of the data processing activities carried out by its data processors and their sub-processors (if any) as well as the types of personal data processed and the involved categories of data subjects. Moreover, details are provided with regard to the service provider’s obligations in its role as data processor which include indicatively its confidentiality obligations, the procedure to be followed in case of a data breach incident, cooperation regarding inquiries from data subjects and authorities, assistance for the performance of data protection impact assessments, international data transfer mechanisms to be executed in the case of cross border data transfers, specific rules for the due diligence and engagement of sub-processors, implementation of appropriate security measures and personal data breach indemnification commitments.
Our service providers are required to be transparent and inform us in advance about their affiliates and any external collaborators (acting as sub processors) that might be involved in processing activities. In case that a service provider and/or any of its collaborators, are located outside UK, we request where necessary that they also execute appropriate data transfer mechanisms with such third parties to cover any onward transfers; in particular the Standard Contractual Clauses (SCCs), in the absence of an adequacy decision and/or any other data protection related certifications implemented by such third parties. This approach establishes and maintains a high level of data protection and privacy for the individuals we interact with in the UK and beyond.
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. Your personal data will be disclosed only in accordance with applicable laws, and appropriate safeguards through contractual agreements, will be established to protect your personal data.
Detailed information on the names of the data processors can be requested by emailing the Santen EMEA Privacy Office at firstname.lastname@example.org.
Security and data retention
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy, applicable data protection laws and regulations as well as international security standards. All data you provide to us is stored on secure servers and accessed and used subject to our security policies and standards. Santen has implemented reasonable physical, technical and managerial controls and safeguards to keep your personal data protected from unauthorised access, disclosure, alteration, and destruction. Such measures may include, but are not limited to: firewalls, access controls, encryption of information while it is in storage, separation of duties, and similar security protocols. Access to your personal data is limited to a restricted number of Santen employees whose duties reasonably require such information and third parties with whom Santen contracts to carry out business activities on its behalf. Our employees have been trained on the importance of privacy and how to handle and manage personal information appropriately and securely.
We will retain your personal data for the time strictly necessary to achieve the purposes for which the data were collected and any other permitted associated purpose. Data may be retained for a longer duration where applicable laws or regulations require, or allow Santen to do so. When your data is no longer needed it will be either irreversibly anonymised (and the anonymised information may be retained) or securely destroyed.
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;
- Update 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;
- Provide you or a third party, with a copy of your data in a digital format (data portability);
- Stop a particular processing when you withdraw your consent;
- 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 privacy EMEA office at email@example.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. Further information and contact details of the UK competent supervisory authority (Information Commissioner’s Office) can be found here.
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.
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 privacy EMEA office by email at firstname.lastname@example.org.
Last updated: November 12, 2020