Introduction
Wellinq (hereinafter collectively “Wellinq”, “we” or “us”) are committed to protecting your privacy and Personal Information and to respecting your rights. This Privacy Policy describes how we collect, use, share, transfer, store and secure (collectively “process”) the personal information of you, our customers, vendors, healthcare professionals, patients, donors, clinical trial subjects, product/service users, website visitors, job applicants, employees, shareholders and other contact persons (“Data Subjects”).
“Personal Information” is any information relating to you, which can be used to personally identify you, either directly or indirectly.
If we decide to change the way we process your Personal Information, we will post those changes in this Policy. For some changes, we will notify you more prominently and/or give you prior notice, depending on the legal requirements we will have to comply with. We reserve the right to make changes to our practices and this Policy at any time provided that we follow the procedures above.
This Policy may not address all possible data processing. In some cases, we may provide you with more detailed notice (such as sending you a notification or through other supplementary policies) in relation to the processing of your Personal Data.
If you have any questions or concerns about this Policy or the way we collect, store and use your Personal Information, don’t hesitate to contact Wellinq, info@wellinq.com
Basic principles
1. Compliance with laws
Wellinq processes your Personal Information in accordance with applicable laws and regulations.
2. Use of Personal Information
When Wellinq collects your Personal Information, Wellinq notifies the purpose of use of Personal Information to you and never uses it for other purposes than the purpose of use notified to you without prior notice or your consent, unless the use for a compatible purpose is allowed by the applicable law.
3. Security of Personal Information
Wellinq takes security measures technically and organizationally to prevent loss, destruction, falsification, divulgence or leakage to outside Wellinq of and unauthorized access to your Personal Information. Such measures include access rights management, monitoring of access, anonymization, pseudonymization, careful selection of processors, written agreements with processors, training to our employees and other technically and commercially reasonable measures to provide appropriate protection of your Personal Information.
Types of information we collect
We may collect and use the following types of information depending on your relationship with Wellinq (some information listed below is not Personal Information depending on the applicable laws):
Types of information Examples
Contact information and identification data such as your name, address, e-mail address, telephone or mobile phone number, your signature , gender, birth date.
Official identification numbers such as your VAT Tax number, your passport number (when we help you obtaining a permit), your national ID number,
Financial data such as your bank account number and bank details, payment terms and credit limits (for suppliers)
Professional data such as your language skills, professional knowledge or expertise, certifications, references and other information you could find on a resume, your job title and the company you work for, any mandates you may hold, your professional location and travel data (for business contacts we know are flying in to attend an event), your professional remuneration, evaluation and performance reports (e.g. for our consultants), your memberships or network contacts (e.g. when we meet you at an event or get in touch with you through someone within your network)
Electronic localization data such as your whereabouts on the premises (based on badge data)
Preferences, interests, lifestyle or behaviour such as the products or activities you are interested in, the events you attend, the news or information you have requested or, your purchasing history (e.g. also through logs, expenses, …)
Health and clinical data such as medical certificates of employees/contactor; clinical data, health data, medical history, testing results, medical images and other relevant data included in the hospital patient file
Image data such as photographs, radiographic images, pictures, videos, surveillance images
Data of website visitors Such as IP address, geographical location, operating system, information about your visits and use of our websites
In addition to the information types listed above, we may collect and use other types of information relating to you that you may have voluntarily provided to us, that may have been provided to us in the context of our business relations or that we may have deducted or generated from information that were already in our possession.
Source of your information
We may collect your data that you have voluntarily provided to us (for example by applying or registering for an event, visiting our booth at a congress, participating in trade fairs, webinars, seminars, training events, by submitting your resume or business cards, responding to a survey or participating in a website feature, or by contacting us by phone) or that was provided to us by the company or organization you work for.
We may receive or indirectly collect your Personal Information from other sources such as our business partners, data brokers, or public sources such as social networks, public websites and social media (e.g. Facebook, LinkedIn, X, Instagram, WeChat).
Purposes of use of the information held by Wellinq
We may use your Personal Information for one or more the following purposes:
(a) To contact you for specific requests or inquiries (for example to obtain consultancy services, to respond to your queries);
(b) To manage our business relationship;
(c) To communicate with you (via meeting, regular mail, email, telephone or other means) about our products and/or services;
(d) To share with you information that might be of your interest;
(e) To identify your interest as an existing or potential customer or user in particular products or services for marketing and product/services promotion (prospecting and profiling), to provide you better support and to better respond to your inquiries and needs and of those of our patients;
(f) To invite you to provide feedback or participate in customer surveys, market research and surveys to develop or improve our products and related services;
(g) To use this information for our overall customer relationship management (CRM);
(h) To authorize you to access Wellinq’s website (“our website”);
(i) To manage tenders, orders, logistics and collection of payments;
(j)To perform pre- and post-market research, including clinical trials (with patients);
(k) To perform research or survey in the fields of medicine, pharmacology and medical devices;
(l) To manage product failures and recalls;
(m) To manage grants and donations;
(n) To consider and handle your recruitment (for example when you apply for a job through our website) or contactor relationship;
(o) To manage your work, salary payment, evaluation, development of ability, welfare, health and safety and other HR-related matters;
(p) To contact you in emergency situations such as natural disasters;
(q) To communicate with you about your rights and benefits as shareholder (for example sending notice of shareholders’ meeting, business report and other distributions and to deal with the affairs related to the exercise thereof;
(r) To guide and treat you when visiting our facilities and to manage your inquiries, your answers to our questionnaires and so on after your leaving our facilities;
(s) To protect our legal rights (including disputes and litigation) and ensure security and protection of our organization, our customers, patients and the public in general;
(t) To comply with laws, regulations, industry standards (such as vigilance reporting and transparency reporting), public authority requests, and court orders;
(u) To prevent and detect fraud and other offences and to ensure compliance;
(v) To notify you about changes to our website and ensure the ongoing accuracy and relevance of your data.
(w) To provide patient support and donor support
(x) To process payments
(y) To develop and improve our products
(z)To acquire regulatory approval from health authorities
Retention period
We only keep your Personal Information for as long as it is necessary for the purpose listed above or is required by law. However, we may be obliged to store some Personal Information for a longer time, taking into account factors including:
the establishment, exercise or defense of legal claims (e.g. for the purposes of a potential dispute).
Whilst we continue to process your Personal Information, we will ensure that it is treated in accordance with this Policy. Otherwise, we securely erase or anonymize your Personal Information once it is no longer needed.
Data subject’s rights
Depending on the applicable law to the processing, you may have the right to:
To be informed about how we process your Personal Information
Access your Personal Information
Correct your Personal Information
Delete your Personal Information
Restrict processing your Personal Information
Lodge a Complaint about the processing of your Personal Information
You can request the exercise of your rights by following the guidance in the privacy policy of the involved group company linked at the bottom of this page.
If you are not sure which our group company you provided your Personal Information, please contact Wellinq at info@wellinq.com.
Results of unavailability of your Personal Information
Providing personal information to us is voluntary on your part. You can choose not to provide us your information, however if you do, we may not be able to provide you with the applicable products or services, and you may not be able to use all the interactive features of our websites.
Providing the information to third parties
Wellinq will not sell, rent, distribute or otherwise make Personal Information commercially available to any third-party except your consent to us doing so.
(a) Service providers
We also share your Personal Information with our third-party service provides as necessary. We carefully select these service providers and take steps to ensure that your Personal Information is adequately protected. All of our service providers are bound by written contract to process Personal Information provided to them only for the purpose of providing the specific service to us and to maintain appropriate security measures to protect your Personal Information.
(b) Health authorities, industrial associations
We may be required to disclose your Personal Information to health authorities and industrial associations in order to comply with the regulations on such as vigilance, transparency report, clinical trial, application for regulatory approval, product recall and other reports.
(c) Other authorities
We may also be requested to disclose your Personal Information as required by other authorities such as ministry, court, tax agency, local government office under laws, regulations, court orders or administrative orders. In this case, only the information specifically requested is disclosed.
(d) Acquirer, investor
We may disclose your Personal Information to our potential acquirer or investor in case of merger, acquisition, assignment, joint venture or other corporate transactions related to Wellinq.
