Version Date: 28 November 2018.
Scope of this Privacy Notice
Biogen, Inc. of 225 Binney Street, Cambridge, MA 02142, USA (“Biogen”) has created this neurology website Neurodiem to provide information, education and tools to neurosciences healthcare professionals to stay up-to-date in their medical and scientific knowledge. This Privacy Notice describes what “personal data” (meaning any information relating to an identified or identifiable natural person) we need to collect from you on the website, how we use it and why, as well as your rights in relation to this collection and use. You are under no obligation to provide personal data to us, but should you decide not to, you will be unable to gain complete access to the website and its content.
Information we collect and how we use it
The website collects different types of personal data depending on how you use it.
If you choose to register to use the website, you will need to create an account and user profile on the website. We may collect the following necessary personal data from you to do this: your name; title; e-mail address; password; postcode; and practitioner/physician licence or identification number. It is in Biogen’s legitimate interest to process your personal data in this way, and we require this information to: (a) verify that you are a neurosciences healthcare professional; (b) create and manage your account; (c) tailor your user experience and provide you with information that matches your specialty and areas of interests; and (d) provide you with local technical and administrative support, where necessary.
The website gives you access to various tools and content on neurology (including articles, publications and videos). Your personal data mentioned in the “Website registration” paragraph above will be used to tailor some of this content specifically to your specialty and previous preferences.
If you provide your consent by ticking the relevant tick box on the website during registration or within the account preferences page, Biogen will use your personal data to send you direct marketing communications (including newsletters, therapy information, insights about diseases, clinical trial information, patient education materials, and invitations to attend meetings or congresses or participate in market research surveys). You may unsubscribe from, and withdraw your consent to, receiving such communications at any time and you may also manage your preferences on the website by logging in to your account. This does not, however, affect the lawfulness of the processing before your withdrawal of consent.
Data collection technologies, interest-based advertising and “Do Not Track”
The website collects aggregated personal data from you to assess how it is being used.
(a) Google Analytics - It does this by using specific tagging technology called Google Analytics which provides Biogen with information on how the website is being used, including preferences, which pages have been visited, which resources have been read, shared or downloaded, which videos have been watched or shared and the progress of any resources being read or watched. Biogen analyses this information automatically, using an algorithm designed to improve the website and to deliver content tailored to its user’s specialty and areas of interests. The website also uses Google Analytics to collect aggregated personal data from you to assess: (a) the number of times the website is visited; (b) the number of accounts that are created; and (c) the amount of times an article is read or a video is viewed. This data collection technology allows us to distinguish you from other users of this website and to enhance this website and your experience when you use it.
(b) Hotjar – We also use Hotjar to analyse users’ behaviour in their usage of the website to improve the user experience.
We also use Facebook Matching and DoubleClick Manager, to manage our online advertising programme. These data collection technologies are provided by our ad management partners and other third parties. We, and our ad management partners, may use the technologies to track the actions of users of the website, to measure statistics of our marketing efforts, and to deliver advertisements on third party websites. We support the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance. This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these principles can be found at www.aboutads.info. If you want to “opt out” of receiving online interest-based advertisements, please follow the instructions at www.aboutads.info/choices or www.networkadvertising.org/choices. An “opt-out” cookie will be placed on your device indicating that you do not want to receive interest-based advertisements. If you delete cookies on your device generally, you will need to opt-out again. Please note that when you “opt-out” of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us. It means that the online ads that you do see will not be based on your interests. When you “opt-out” of receiving interest-based advertisements through one of the links above, these data collection technologies may still collect information about your use of the websites, including for analytics.
How we share your information and international transfers
Biogen engages service providers to assist it in the administration of its data processing activities in relation to the website (known as “data processors”). These include the companies which: (a) provide Biogen with validation that you are a neurosciences healthcare professional; (b) help us to improve the content and design of our website; (c) provide you with direct marketing communications on our behalf, if you have provided your consent to receiving them; (d) provide Biogen with technical and administrative support; (e) provide Biogen with data collection technologies and interest-based online advertising; and (f) host the website and your personal data in the cloud and provide Biogen with data storage facilities.
Other Biogen companies
Biogen may also share your personal data with other companies in the Biogen group for the purposes described in this Privacy Notice including Biogen International GmbH, Neuhofstrasse 30, 6340 Baar, Switzerland. If a third party acquires all or a material part of Biogen's business or assets, then your personal data may be disclosed in connection with that sale.
Ensuring protection of your data
The transfers mentioned above may include transfers outside of your country to countries which do not implement an adequate level of protection for your personal data under your national or under European Union data protection law. Biogen takes appropriate steps to ensure your data is adequately protected if transferred to such countries. Switzerland is a country deemed to provide an adequate level of data protection under its data protection laws by the European Commission. Biogen otherwise has EU-approved standard contractual clauses in place where necessary to provide an adequate level of data protection. Upon your request, Biogen will provide you with a list of all recipients of your personal data and/or further information on any data transfer agreements with recipients outside the European Economic Area.
How we store your personal data
We retain your personal data as long as your account remains active and you may deactivate your account at any time. We will also retain your information for as long as is necessary for us to comply with our legal obligations and best practice for a responsible pharmaceutical company.
You may contact Biogen at any time if you would like to access and receive your personal data or require information about the personal data that we hold about you. You may object to or restrict the processing of your personal data for legitimate reasons and you may also request the correction, blocking or erasure of it. You may also choose to opt-out of receiving any direct marketing e-mails you have previous expressed an interest to receive. Please note that some of these rights are limited by applicable data protection law and we have the right to collect, process and hold your personal data to perform our legal obligations.
You may, should you feel it necessary, lodge a complaint with your local data protection authority if you feel your privacy rights have been infringed.
Under European data protection Law, a "data controller" is the legal entity that is responsible for protecting your personal data and helping you to exercise your data protection rights. The data controller of your personal data is Biogen. If, at any time, you have questions or concerns about this Privacy Notice or the processing of your personal data, you can contact Biogen by sending an e-mail to email@example.com or by using the “Contact Us” feature on the website. You may also contact Biogen’s Data Protection Officer at firstname.lastname@example.org.