Focus Care Privacy and Cookie Notice 

Introduction

This privacy and cookie notice (“Notice”) is provided by Focus Care B.V.. Focus Care is referred to in this Notice as “we”, “us” and “our.”

This Notice is intended for:

• users of Focus Care products and services;
• visitors to Focus Care owned websites;
• members of the general public who are interested in contacting or are being contacted by Focus Care.

We understand that privacy is important to you. We are committed to treating your personal information with care and integrity. This Notice tells you what personal information we collect and how we collect it, what we use your personal information for and how we protect your personal information and keep it safe.

In order to make this Notice more accessible, it has been prepared in the form of questions and answers (Q&A). Click on a question to find the answer and background information. If your question is not listed, please feel free to contact us by phone or email.

1. Who is the controller of my personal data?

Focus Care is the controller of your data.

2. What is the scope of this Notice?

This Notice applies to most of our general processing of personal data, including when you interact with us as a customer, supplier, healthcare professional or other general member of the public, and when you visit or use our websites, and other digital properties (such as apps) or platforms (each, a “Site”).

Our Sites may include links to other websites or organizations over which we have no control. Focus Care is not responsible for the privacy policies or practices of other websites or organizations. If you access these websites via our Sites, you should review the privacy policies of those sites so you can understand how they collect, use and share your personal data.

3. How does Focus Care collect my personal data?

Directly from you when you:

• Create an account and profile on one of our websites, or apps;
• Use our websites, apps and systems;
• Share or use your social media profile to contact us;
• Sign up with us to receive promotional material;
• Engage with one of our sales representatives;
• Get in touch for support or to provide feedback;
• Attend an online event such as a webinar;
• Respond to any surveys that you may choose to participate in;
• Share adverse events or medical information enquiries with us; and
• Attend offline meetings, such as advisory boards or conferences.

From other sources:

• Publicly accessible sources, such as public registers of healthcare professionals, published journals and event materials and from websites of healthcare professionals or their employers;
• Joint marketing partners;
• Marketing vendors;
• Healthcare provider directories;
• Events management agencies;
• Social Media platforms.

If you connect your social media account to our websites, or apps, you will share certain personal information from your social media account with us. This may include your name, email address, photo, list of social media contacts, and any other information you make accessible to us when you connect your social media account to our websites, or apps.

We also combine information about you from various sources, including the information you provide to us and personal information, which is collected during your relationship with us.

4. What personal information does Focus Care collect about me?

The personal information we collect and process, may include:

• Basic information – your personal data, including your name, surname (including prefix or title), alias, gender, age or date of birth, as well as your preferred language;  
• Contact information – information that enables us to contact you, e.g. your personal or business email, mailing address, telephone numbers and profile on a social media platform; 
• Technical and network activity information – information about your device and your usage of our websites, apps and systems, including your IP address, device ID, hardware model and version, mobile network information, operating system and other online identifiers, type of browser, browsing history, search history, access time, pages viewed, URLs clicked on, forms submitted, and physical location;
• Financial information – your bank details, including account name, account number and sort code;
• Suppliers/vendors and customers – your personal data, including your name, personal identification number, professional contacts, business bank account details and other related information and financial information, order/payment data, survey responses where applicable, and other appropriate records of our interactions with you.
• Product use – data related to your use of our products (including feedback), your purchase history and preferences, your interactions with us, your preferred method of communications with us, and services you may use;
• Health information – your health status, health conditions you are experiencing and health information inferred from information that you have provided to us

You can choose not to give us personal information when we ask you for it. If you decide not to give us your personal information, it may restrict our relationship with you. For example, we may not be able to provide you with the services that you have requested.

5. For which purpose does Focus care use my personal data?

a. To manage our contractual relationship with you

We process your personal data when it is necessary for the performance of a contract with you, or where you have requested us to take steps prior to us entering into a contract together, such as:

• to fulfil any of our obligations owed to you under such contract such as to manage your orders, arrange the provision or receipt of goods and services, and to make payments to you for services provided, the reimbursement of expenses or rebates;
• managing orders, questions and complaints regarding products where you have placed orders, posed questions in relation to orders, or submitted complaints.

b. Legal obligation

We process your personal data to meet legal (including tax and accounting), regulatory, pharmacovigilance, quality, medical inquiry and compliance requirements, such as:

• to respond to requests for information from government authorities;
• to comply with all legal and self-regulatory obligations including transparency and disclosure obligations or anti-gift obligations (this may either be in our legitimate interests or a legal obligation);
• to manage and respond to requests concerning quality or medical information (this may either be in our legitimate interests or a legal obligation);
• prior to entering into a personal services contract with you, to check that your professional expertise and experience match our identified need for that service.
• To enable us to comply with data protection law by maintaining records of any consents, preferences or other settings.

c. Legitimate interests

We also process your personal data when it is necessary for the purposes of our legitimate interests as a controller (or those of a third party).

d. Consent

Generally we do not rely on consent as a legal basis for processing your personal data, expect for certain circumstances such as sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

If we require your consent to process your personal data in any other circumstances we will contact you separately to request such consent.

We will use your personal data only for the purposes for which it was collected, unless we reasonably consider that we need it for another purpose that is compatible with the original purpose. If we need to use your personal data for an unrelated but compatible purpose, we will notify you in advance of our use of your personal data and explain the legal basis for this. Note that we may process your personal data without your knowledge or consent where this is required or permitted by applicable law.

6. With whom does Focus Care share my personal data?

Your personal data can be accessed by a restricted number of our employees who are trained about the importance of privacy and how to handle and manage personal data appropriately and securely.

Depending on the content of your request, we may share your personal data to our affiliated entities and/or to third parties. We will only use third parties providing sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will meet the requirements of applicable law and ensure the protection of your rights.

7. How does Focus Care use Cookies on its sites?

Focus Care uses cookies and similar technologies to collect information about you and store your online preferences. Cookies are text files containing small amounts of information which are downloaded to your device when you visit a Site. Cookies are then sent back to the website when you return to it: this is useful because it allows the website to recognize your device.

Focus Care uses the following categories of cookies on the Site:

1: Strictly Necessary Cookies

These cookies are necessary for the Site to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Site will not then work.

 2: Performance Cookies

These cookies collect information on how people use and interact with the Site. We use these cookies to help us understand how users arrive at the Site, browse or use the Site and highlight areas where we can improve such as navigation, user experience and marketing campaigns.

3: Functional Cookies

These cookies are set to enhance functionality and personalization on the Site. These can then be used to provide you with an experience more appropriate to your selections and to make your visits to the Site more tailored. The information these cookies collect may be non-directly identifiable.

 4: Social Media Cookies

These cookies are used when you share information using a social media sharing button or “like” button on our Platforms, or when you engage with our content on or through a social site such as LinkedIn or Twitter. These cookies collect information about your social media interaction with the Site, such as whether or not you have an account with the social media site and whether you are logged into it when you interact with content on the Site. This information may be linked to targeting/advertising activities.

 5: Advertising cookies

These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with our permission. They remember that you have visited the Site and this information is shared with other organizations such as advertisers.

6: Email tracking

We may also collect information using web beacons, which give us an indication of the usefulness of the emails we send to you such as whether an email was opened, clicked on or sent to spam, time stamps of the above actions, and what device was used.

We may combine this information with your personal identifier to personalize our messaging to you through our sales reps, emails, mobile or web channels and evaluate the quality of our messaging to you, customer research and benchmarking.

If you would like to avoid web beacons all together in your emails, you may refer to your settings in your email reader program and disable the functionality that enables remote images to load and by refraining from clicking on links or refer to the relevant consent in our cookie management platform.

Where we place cookies directly, we typically keep information collected from cookies for a maximum of 6 months.

8. How can I manage cookie preferences?

If you want to manage your cookie preferences or delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. If you would like to avoid cookies (web beacons) in your emails, you may refer to your settings in your email reader program and disable the functionality that enables remote images to load and by refraining from clicking on links.

Information on deleting or controlling cookies is also available at www.allaboutcookies.org. Please note that by deleting our cookies (or disabling future cookies) you may not be able to access certain areas or features of Sites.

9. Can I withdraw my consent?

Where you have consented to the processing of your data or the use of cookies, you may withdraw such consent at any time. You have an absolute right to opt-out of processing for direct marketing purposes at any time. You can do this by following the instructions in the communication where this is an electronic message or by contacting us using the details set out below. For certain Sites, you may also have an ability to change some marketing preferences online.

10. How long does Focus Care store my information?

If we have a contract with you, your personal data will be retained for the duration of your contract and for an appropriate duration after its termination in your country to protect us from any legal claim.

Otherwise, your information will be retained for two years, or as reasonably necessary for the purposes set out above, in accordance with applicable laws. For more information on your particular circumstance, please contact us using the contact information listed below.

11. What are my rights?

You are entitled:

• to ask Focus Care for a copy of your information;
• to rectify information you think is inaccurate, and to complete information you think is incomplete;
• to erase certain information;
• to restrict its processing, or to ask us to transfer some of this information to other organizations;
• to object to some processing. These rights may be limited in some situations – for example, where we can demonstrate we have a legal requirement to process your personal data;
• to receive your personal data in a structured, commonly used and machine readable
• format and to (have) transmit(ted) your personal data to another organization
  

12. Will my personal data be internationally transferred?

In the event of a transfer of data to countries which may offer a lower level of data protection, we enter into data transfer agreements based on the standard contractual clauses for international data transfers.

13. How can I contact Focus Care?

If you have any concerns about how we process your personal data or wish to exercise any of your rights, wish to obtain other information or would like to raise a concern, you can contact us through the contact page of our website.

14. How can I file a complaint?

You can always contact us if you have a complaint regarding our processing of personal information. If you remain dissatisfied, you can file a complaint with the competent authority. For the Netherlands, this is the “Autoriteit Persoonsgegevens”.

Changes to this Notice

This Notice has been updates in April 2024. It may change from time to time. When we make material changes to this Supplemental Notice, we will notify you by posting an updated Notice on our website and listing the effective date of such updates.