Privacy Notice for Consent to Receive Email Communications
(Applicable to consent requested when registering for event on CSL Behring Academy website)
We, CSL Behring AG, Wankdorfstrasse 10, 3014 Bern, Switzerland, are asking for your consent for us and other companies of the CSL Group (together “CSL”) to send you information (promotional and non-promotional) by email about products, services, offers and events, including without limitation newsletters, invitations to educational events, market research and surveys. We will only send you information which we believe could be of interest to you. We will send the communications to the email address which you provided when registering for an event on the CSL Behring Academy website.
You agree that CSL may personalise its emails to you and make them more useful and relevant based on measurement of your interaction with our email communications. Pixel tags, web beacons and clear GIFs embedded in our emails allow us to track whether, when and where you opened the emails and whether you interacted such as by clicking links in them or in resources to which they referred you.
We will collect the relevant data from the devices (including mobile devices) that you use to access the emails we send you. The data collected and processed includes the following usage- and device-related data:
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Access time, frequency and duration of access to emails we send you, the links on which you click and other actions you take in this context;
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Device type, operating system and version, browser type and settings, device ID or other individual device identifier and individual device token;
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Your user segment; and
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IP address of the device you use to access the email.
For the personalisation, your personal data could be combined with data we hold regarding your professional interests.
Who will have access to your electronic contact details?
We may share your email address and other personal data with other CSL companies to enable them to send you emails. Information about the companies of the CSL Group is available at: https://www.csl.com/we-are-csl/worldwide-locations and at CSL Group Legal Entities | Global Biotechnology Company | CSL. We may also share your contact details with third parties who perform services such as data hosting, IT support and assisting CSL to provide information to you via email. Such service providers include without limitation Microsoft, Inc., Veeva Systems, Inc. and Inxmail GmbH.
Some of the above-mentioned recipients of your personal data are located outside the country where you live, including in the United States, Australia, Switzerland, countries in the Middle East and other countries all around the world, some of which may not be deemed by the competent authorities to provide an adequate level of protection for personal data. In such cases, we ensure that appropriate safeguards are in place to protect your personal data in accordance with applicable law such as the EU standard contractual clauses. A copy of those clauses can be obtained from our Data Protection Officer, who can be contacted as specified below.
For how long will your electronic contact details be kept?
We will not store your email address for longer than necessary for the purpose for which we collected it or as allowed under applicable law.
What are your privacy rights?
You are not under any obligation to consent to receive emails from us. If you deny your consent, or subsequently withdraw it, the only consequence will be that you will not receive unsolicited email communications from us.
If you give your consent, you are entitled to withdraw it at any time, or to change the email address to which you agree to receive emails, by contacting us, the “Data Controller”, in the following ways:
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following the instructions to unsubscribe which are specified in our email communications; or
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sending an email to info@cslbehringacademy.com.
You have certain privacy rights in respect of your personal data such as a right of access, correction, restriction of use, erasure, and portability. If you wish to exercise your rights, or if you have questions about our use of your contact details, please contact us as specified above or submit a request via the CSL Data Subject Request Portal: https://privacyinfo.csl.com/.
You can contact our Data Protection Officer at privacy@cslbehring.com. You are also entitled to submit a complaint to a supervisory authority if you wish.
Customer Communication Consent
CSL Behring AG, Wankdorfstrasse 10, Bern 3014 Switzerland („CSL Behring“), would like to add you to its contact database and intends to use your name and contact information listed below to provide you with information (promotional and non-promotional) about products, services, offers and events, including newsletters, invitations to educational events, and for market research as well as for surveys. Your consent is required in order for CSL Behring to use your personal data for direct marketing purposes.
Personal Data:
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Consent:
I agree to receive the information selected above by the following means:
□ telephone (representative call),
□ electronic communication: e.g.: email, video calls, Veeva Engage etc
□ SMS
□ postal mail,
I declare that I have read the Privacy Notice below and consent that my personal data provided above are processed for such purposes as described in said Privacy Notice. I have been informed of my rights as data subject in accordance to the applicable law.
By accepting the consent you agree that CSL Behring may personalize the communication with you and provide you with information that is more relevant based on measurement of your interaction with email communication you receive from CSL Behring using pixel tags, which involves automated decision-making, including profiling as explained below in the Privacy Notice for Customer Communication:
I also agree to receive the information selected above by means of personalized and more relevant communications, using pixel tags as outlined above. I consent that my personal data described above are processed for such purpose (including being transferred to and stored in another jurisdiction). I have been informed of my rights as data subject in accordance to the applicable law.
Providing your personal data is voluntary. If you do not provide your personal data, our ability to process your personal data for the purposes selected by you, in particular, to contact you by the means selected by you, will be limited or excluded.
You may withdraw your consent at any time, with effect for future processing, by submitting a respective notice to the contact address given in the Privacy Notice. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
You may also opt out by following the instructions provided in any of the communication mentioned above (except for telephone calls).
For further information regarding the processing of your personal data and regarding your rights, please see our Privacy Notice for Customer Communication overleaf.
Privacy Notice for Customer Communication
Date of last update: 14.12.2022
This is the Privacy Notice for Customer Communication of CSL Behring AG, Wankdorfstrasse 10, Bern 3014 Switzerland ("CSL Behring", "We", "Us"), which sets out the basis on which we will collect and process your personal data.
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Categories of personal data, purposes and legal basis for data processing and categories of recipients
Your personal data will be collected and processed:
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for the marketing communication and purposes chosen by you in the consent form (e.g. send you information about our products and services via email);
The collection and processing of your personal data will take place based on your consent (pursuant to applicable data protection law and when required to comply with applicable data protection and privacy laws).
The processing of your personal data will take place:
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until you withdraw your consent (which may be anytime, with effect for future processing) or object to a use of your personal data for marketing purposes (please use the below contact details to withdraw your consent or object to a use of your personal data)
To personalize the marketing communication with you and to provide you with more relevant information we (based on your choices and explicit consent)
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rely on the information provided by you, your choices and the interests you indicated (identify and apply correlations) when you gave your explicit consent; and
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measure your interaction with email communication we send you using pixel tags which involves automated decision-making, including profiling, which is further described as follows:
Pixel tags (also known as web beacons or clear GIFs) are small graphic images that are used in connection with emails we send you. The pixel tags allow us to track if you opened the emails, clicked links to measure campaign performance, and improve features.
We use pixel tags to personalize customer communication and advertisements based on your interests. This includes using technologies to determine how relevant the content of emails is for you, when and where you opened marketing emails and if you have reacted by carrying out an activity – such as clicking on a link or purchasing an item.
We collect the relevant data from the devices (including mobile devices) that you use to access the emails we send you. The data collected and processed includes the following usage- and device-related data:
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Access time, frequency and duration of access to marketing emails we send you, the links on which you click therein and other actions you take in this context.
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Device type, operating system and version, browser type and settings, device ID or other individual device identifier and individual device token.
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Your user segment.
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IP address of the device you use for email access
For the personalization, your personal data will be combined with data already collected regarding your interests.
Providing your personal data is voluntary and not necessary to enter into a contract with us. If you do not provide your personal data, our ability to process your personal data for the purposes selected by you, in particular, to contact you by the means selected by you and personalize marketing communication, will be limited or excluded.
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Data Protection Officer
You can contact our data protection officer at:
privacy@cslbehring.com You may submit complaints concerning our handling of personal data to the data protection officer.
We will provide a response to your request or complaint within the timeframe established by applicable data protection law. If it is not possible for us to respond to your request or complaint within the required period, we will notify you of the reason for the delay and the extension needed to provide a response. We may require you to provide additional information necessary to confirm your identity before we comply with any request made by you.
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Categories of recipients
To process your data for the purposes chosen by you CSL Behring uses service providers (e.g. hosting, IT-support and/or maintenance providers).
We may disclose your information to other CSL group companies in countries such as the United States of America, Russia, Turkey, Switzerland, Colombia, Brazil, Chile, Argentina, Mexico, Panama, Honduras, Costa Rica, El Salvador, Ecuador, United Arab Emirates, Egypt, Saudi Arabia, Iraq, Jordan, Tunisia, Algeria and other countries within the EU and Middle East and Africa for the purposes set out in this Privacy Notice.
CSL Behring may transfer your personal data to service providers and/or instruct them to process your personal data.
The following service providers are used:
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Veeva Systems, Inc.
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INXMAIL
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Storage duration and erasure
Your personal data will be stored by CSL Behring and/or our service providers in accordance with applicable data protection law to the extent necessary for the purposes set out in this Privacy Notice.
If CSL Behring no longer requires your personal data for the above-mentioned purposes the personal data will be deleted from our systems or anonymized in line with our data retention and deletion policy, unless CSL Behring is legally obligated to retain your personal data pursuant to e.g. tax or trade law or for accounting or auditing purposes.
We will retain your personal data up to one year after the last contact with you on the basis of the consent form, unless CSL Behring is legally obligated otherwise. As far as legally permissible or required, we restrict the processing of your data instead of erasing it (e.g. by restricting access to it). This applies in particular to cases where we may still need the data for the performance of contract or for the assertion of or defense against legal claims. In these cases, the duration of the restriction of processing depends on the respective statutory limitation or retention periods. The data will be erased after the relevant limitation or retention periods have expired.
We take appropriate steps to secure the safety of your personal data pursuant to the applicable laws and regulations.
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Transfer of Data
Where permitted by local law, we may transfer your personal data to jurisdictions other than your own, which may not have equivalent data protection laws to those in your home country. Such transfers will only be made having ensured appropriate technical and organizational security measures are in place, and such information will be protected in accordance with standard privacy contracts or other measures that address applicable international data transfer restrictions.
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Your rights
Pursuant to applicable data protection law you may have the following rights (which might be limited under the respective applicable national data protection law). To exercise your rights please contact us as stated above. In addition to the below rights, you also have the right to lodge a complaint with the competent data protection supervisory authority (where such authority has been established):
- Right of access: You may have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data. The access right includes – inter alia – the right to be provided with information on the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed within or outside the country. However, this is not an absolute right and the interests of other individuals may restrict your right of access.
- You may in connection with the right of access have the right to obtain a copy of the personal data undergoing processing, in accordance with applicable data protection law. For further copies requested by you, we may charge a reasonable fee based on administrative costs, in accordance to with data protection laws.
- Right to rectification: You may have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
- Right to erasure ("right to be forgotten"): Under certain circumstances, you may have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.
- Right to restriction of processing: Under certain circumstances, you may have the right to obtain from us restriction of processing your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes.
- Right to data portability: Under certain circumstances, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those data to another entity without hindrance from us.
- Right to object: Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data. Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer be processed for such purposes by us.