Sinclair Pharma Privacy Policy

Effective 1st January 2020.

Sinclair Pharma is made up of different legal entities, details of which can be found here

This privacy policy is issued on behalf of the Sinclair Pharma Group so when we mention "Sinclair Pharma", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Sinclair Pharma Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. Sinclair Pharma Limited is the controller and responsible for this website.

Sinclair Pharma Limited and its group companies (‘Sinclair Pharma’) respect your privacy and are committed to protecting your personal data. We want to make sure you understand what personal information we may collect about you when you interact with Sinclair Pharma, how we use your personal information and how we keep it safe.

Purpose of this privacy policy

This privacy policy aims to provide you with information on how Sinclair Pharma collects and processes your personal information (information that can identify you), including any data you may provide through Sinclair Pharma’s website or when you sign up for information relating to our products and services, and also anonymous data (information that cannot identify you).

It is important that you read this privacy policy, together with any other privacy notice or fair processing notice we may provide when we are collecting or processing personal information about you, so that you are fully aware of how and why we are using your data. Certain sections of this privacy policy apply to EU, UK or California residents and citizens only, and where this is the case, it is indicated below.

This privacy policy supplements any other notices and is not intended to override them.

This privacy policy explains:

1. What personal information we collect about you
2. How we use your personal information
3. Why we use your personal information
4. How we share personal information with others and whether we transfer it internationally
5. Third Party Websites
6. How we protect your personal information
7. How long we keep your personal information
8. How you can control your personal information - Opting out
9. Your rights regarding your personal information
10. How we use cookies and where to find further information
11.  How you may contact us We may change this privacy policy from time to time and we encourage you to review it periodically.

If you have any questions, please get in touch by contacting GDPR@sinclairpharma.com.

1. What personal information we collect about you

Personal information (or personal data), has the meaning provided by the EU General Data Protection Regulation of 2018 (the “GDPR”) and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (the “UK GDPR”), and means any information about an individual from which that person can be identified. For California residents, personal data has the meaning defined by the California Consumer Privacy Act (“CCPA”). Personal information (or personal data) does not include data where the identity has been removed (anonymous data).

We may collect personal information from you in the course of our business, including through your use of our website(s), when you contact or request information from us, when you buy our products or engage our services, or as a result of your relationship with one or more of our staff and clients. We also use cookies to collect anonymous data, which we then use to provide and improve our services.

Please note our websites are not intended for children and we do not knowingly collect data relating to children (i.e. any person under the age of 18).

The personal information we may collect, use, store and transfer when you interact with us include:

Information you provide to us, such as:

• Basic information, such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person;
• Contact information, such as your postal address, email address(es) and phone number(s);
• Financial information, such as payment-related information; Information that you provide when you create an account on our websites, or subscribe to our service or publications, request marketing to be sent to you, enter a competition or promotion, or register for a webinar event;
• Information you provide to us for the purposes of attending meetings and events, including access and dietary requirements;
• Identification and background information provided by you or collected as part of our business acceptance processes;
• Personal information provided to us by or on behalf of our customers and/or partners or generated by us in the course of providing services to them, which may include special categories of data;
• Your responses to any preferences, feedback and survey responses; Personal information provided in the event that you report a possible side effect associated with one of our products which may include information such as your gender, date of birth and information about your health; and
• Any other information relating to you which you may provide to us from time to time.
• Technical information, such as through the use of cookies, including:

Information from your visits to our website or applications or in relation to materials and communications we send to • you electronically;

• Your activity data, such as your login information and whether you completed a registration form on this website;
• Information regarding your movements on our websites including your IP address(es), browser type and version, access times, pages viewed, URLs clicked on, time zone setting and location and other technology on the devices you use to access our websites, such as unique device identifiers, hardware model, operating system and mobile network information;
• Social media tracking pixels that allow platforms such as Facebook, LinkedIn and Twitter to interact with our websites • and provide feedback on your actions; and
• Marketing and communication data, which includes your preferences in receiving marketing from us and third • parties and your communication preferences.

Information provided by third parties or publicly available sources, such as:

• Technical data from the following :
  • Analytics providers, such as Google, based outside the EU and the UK;
  • Through our monitoring of other websites, which includes your public personal information, such as when we monitor digital conversations on public platforms to understand what people are saying about Sinclair Pharma, our products or the aesthetic dermatology industry in general.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract that we have with you and you fail to provide that data when requested, we may not, as a consequence, be able to perform the contract. For example, such information may be needed to provide you with requested goods or services. In such instances, we may find it necessary to cancel a contract with you and will notify you if this is the case.

2. How we use your personal information

Sinclair Pharma collects and processes personal information about you in a number of ways, including through your use of our website and in the provision of services by us. We use that information to:

• • Provide you with information about us and our services including:
  • online events, such as webinar events;
  • our press releases;
  • job opportunities and recruitment processes;
  • financial results; and
  • marketing communications about our products and services, publications and details of events. Please however note that we will always obtain your consent for marketing communications where required by law.

• • Make contact with you in order to:
  • respond to any requests that you have made (such as enquiring about information relating to our products and services);
  • investigate any complaints or adverse events that you have made in respect of our products and/or services;
  • provide important notices and updates, such as changes to our terms and conditions and policies, legal updates or any security or safety alerts and administrative messages; and manage and administer our relationship with you and our clients/customers.

• Facilitate the successful running of our business, including to:

• • respond to any reports made of possible side effects or adverse effects associated with any of our products;
  • comply with any demands or requests made by regulators, courts of law, governments and law enforcement bodies;
  • perform a contract, such as engaging with individuals and other third parties to provide our products and services;
  • ensure we are pursuing legitimate business purposes; ◦ comply with applicable laws and regulations;
  • investigate, and take action where required, in response to any illegal, criminal or harmful behaviour;
  • improve our day-to-day business operations, including data analysis, auditing and research to help us to maintain and improve our digital platforms, content and services;
  • monitor trends, usage and activities in connection with our products and services to assess and understand our  most popular digital platforms and services and to improve these accordingly; fulfil our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims;
  • improve and update our products, services and communications to you; and ensure we have up-to-date contact information for you (where applicable).

Use of Sinclair Pharma’s website

A number of facilities on our website invite you to share your personal information with us, such as through the ‘Careers’ section of the website and our email queries facilities. Where information is provided via use of such facilities we shall only use your personal information for such purposes.

Marketing and other emails

We use personal information to understand whether you read our emails and other materials (such as details of events) that we send to you, whether or not you click on the links to the information we include in them and whether and how often you visit our website after you click on such links (both immediately and on future visits). We do this by using software that places a cookie on your device to track activity and record it against your email address. Please see the section ‘How we use cookies and where to find further information’ below for further information.

If you receive marketing communications from us and no longer wish to do so, you may unsubscribe at any time by emailing us at GDPR@sinclairpharma.com.

Meetings, events, conferences

We will collect and process personal information about you in relation to your attendance at our offices or at an event or conference organised by Sinclair Pharma or our third party partners. Where information is provided in this manner we will only process and use special categories of personal information about your dietary, medical or access requirements in order to cater for your needs and to meet any other legal or regulatory obligations we may have. We may, however, where necessary, share your information with IT and other service providers or business partners involved in organising or hosting the relevant event.

Our services

We collect, create, hold and use personal information in the course of and in connection with the services we provide to our partners and customers. We may process identification and background information as part of our business acceptance, finance, administration and marketing process, including reputational and financial checks. We will also process personal information provided to us by or on behalf of our customers and/or partners for the purposes of the services we provide and the work we do with them. The information may be disclosed to third parties to the extent reasonably necessary in connection with that work. Please see the section ‘How we share personal information with others and whether we transfer it internationally’ for more information.

Automated Decision Making and Profiling

We do not use your personal information for automated decision-making, unless we are required to do so by applicable laws, in which case we will inform you of such processing and provide you with an opportunity to object.

3. Why we use your personal information

In accordance with data privacy laws, we may rely on a number of different reasons for collecting and using your personal information examples of which are set out below:

• For legitimate business purposes: we want to make your experience of using our products and services as effective and efficient as possible and so we use your personal information to make our communications with you more relevant and personal to you. This helps us to operate our business effectively to ensure there is minimal disruption to the services we may offer to you.
• To perform a contract with you: we may need to register you as a customer, manage payments between us, notify you of any changes to any of our terms or policies, enable you to take part in our promotional activities and of course, provide our products and services to you, all of which will mean we may need to process your personal information effectively and securely.
• To comply with our legal obligations as a business and other demands for information: it is important that Sinclair Pharma is able to comply with applicable laws, regulations and guidance as well as meet the requests or demands for data as set out in this policy to ensure that our products and services are provided to the highest standard.
• You have given your consent: on occasion, we may need to obtain your consent to allow us to use your personal information for certain purposes as detailed in this policy. Please see the section ‘Your rights regarding your personal information’ below regarding the rights you have should we need to process your personal information based on your consent.

4. Sharing personal information with others and transferring it internationally

We may share your personal information with the following:

• Other members of the Sinclair Pharma group of companies;
• Trusted third parties, such as: our agents and suppliers; partners who provide us with technology services, such as data analytics, hosting and technical support; our professional advisors; auditors and business partners; regulators, governments and law enforcement bodies, and other third parties in connection with the re-organising or merging of any part or all of our business. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. Sinclair Pharma, its affiliated companies and its trusted third party suppliers may process your personal information outside of your home country and in any event, outside of the European Economic Area (‘EEA’) and the UK. Data privacy laws in the countries where your personal information may be transferred may not be equivalent to, or as protective as, the laws in your home country. Sinclair Pharma will ensure that appropriate measures to protect and safeguard your personal information are put in place in the event that it is transferred outside of your home country. These measures include securing data transfer agreements by implementing standard contractual clauses.

5. Third party websites

From time to time on our websites we may provide links to websites or mobile applications that are separate to and not controlled by us. This privacy policy does not apply to those websites. Should you choose to visit those third party domains, please ensure that you read the legal and privacy statements posted on each website or mobile application to understand their privacy practices.

6. How we protect your personal information

Sinclair Pharma uses a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection laws. Where we contract with external suppliers, our written agreements commit suppliers to only process your personal data in accordance with our instructions; to keep your information confidential; and to put in place appropriate security measures to safeguard your information. Please note that the transmission to us of information via the internet or mobile phone network may not be completely secure and any transmission of information to us is at your own risk.

7. How long we keep your personal information

Your personal information will be retained in accordance with our data retention policy, which categorises all of the information held by Sinclair Pharma and specifies the appropriate retention period for each category of data. Those periods are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and Sinclair Pharma’s business purposes.

8. How you can control your personal information - Opting out

If you currently receive marketing messages from us and no longer wish to do so, you can ask us or third parties related to us to stop sending you marketing messages at any time by contacting us at GDPR@sinclairpharma.com or unsubscribe from within any such email.

Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a product/service purchase, warranty registration, product/service experience or where otherwise permitted by law.

9. Your rights regarding your personal information (EU, UK and California residents and citizens only)

Under certain circumstances, if you are a resident or citizen in the EU, UK and California, you have rights under data protection laws (GDPR, UK GDPR and CCPA) in relation to your personal information (or personal data).

You are entitled to request details of the information we hold about you and how we process it. You may also have a right, in accordance with applicable data protection law, to have it rectified or deleted, to restrict our processing of that information, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to another organisation. You may also have the right to lodge a complaint in relation to Sinclair Pharma’s processing of your personal information with a local supervisory authority.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above (see ‘How we use your personal information’) or that you may not be able to make use of the services and products offered by us. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.

For California residents and citizens, under the CCPA, you may opt out of the sale of your personal data. Please refer to our ‘do not sell my personal data’ link below. We will never exchange your personal data for money. The CCPA has a very broad definition of “sale”, and it may include browsing data sent to referral advertisers. We will automatically turn these off if you opt out of the sale of your personal data.

Click the following link to opt you out of personalised advertisements on this website: Do Not Sell My Personal Information

We must ensure that your personal information is accurate and up to date. Therefore, please advise us of any changes to your information by emailing GDPR@sinclairpharma.com.

10. How we use cookies and where to find further information

Cookies allow our websites to recognise and respond to you as an individual. You can choose to accept or decline cookies. If you choose to disable or decline cookies, please note that some parts of our websites may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

11. How you may contact us

If you have any questions, concerns, complaints or requests regarding this privacy policy, or if you would like to exercise any of the rights set out above, please let us know by contacting GDPR@sinclairpharma.com or by writing to the contact address below.

In your request, please clearly state which right you would like to enforce and what personal information you are concerned about. We may need to verify your identity before fulfilling your request and we will only fulfil requests associated with the email address your request was sent from. We will action your request in a prompt manner, and, in any case, within 30 days from the date of your request (for requests under the GDPR and UK GDPR) or 45 days from the date of your request (for requests under the CCPA). For EU and UK residents and citizens, if you feel your request has not been resolved adequately, you may contact your local data protection supervisory authority. Under certain circumstances, we may retain information for record keeping or to complete transactions you initiated prior to making your request.

Contact address: Legal Department, Sinclair Pharma Limited, Eden House, Lakeside, Chester, UK, CH4 9QT.