GDPR Privacy Notice for Healthcare Professionals
Introduction
Source of Your Personal Data
Data Processing Overview
Recipients of Your Personal Data
Data Security and Transfers Outside EU/EEA
Your Rights Relating to Personal Data
Automated Decision Making
Changes to the Notice
Contact
Introduction

This Privacy Notice (“Notice”) is designed for healthcare professionals (“you” or “HCP”) whose personal data is included within our product, which is a resource that collects and structures publicly available biographical information concerning healthcare professionals for the purpose of possible business engagements with our corporate customers (“Product”). Our customers are generally companies from the healthcare industry (such as pharmaceutical and healthcare products companies) that desire to have business relationships based on professional knowledge and experience of qualified healthcare professionals. We aim to explain the details of how we process your data in connection with our Product and ensure that your personal data is handled appropriately, in a manner that respects your privacy and meets applicable legal standards.

Aissel Technologies Private Limited (Office No. Lower Ground Floor-01, Next to International Airport, Gokul Road, Hubballi - 580030. India) (“we” or “Aissel”) is the controller in relation to the processing of your personal data under the EU General Data Protection Regulation 2016/679 (“GDPR”) for the purposes stated in this Notice.

The terms "controller", "personal data", "data subject", "processing", and any other terms expressly defined in Article 4 of the GDPR shall have the meaning given to these terms in Article 4 of the GDPR.


Source of Your Personal Data

We collect your personal data from different sources, which are then combined into personal profiles as part of the Product. Depending on the availability of your personal data in publicly available sources, your data may be collected from:

1. Publicly available information, including information obtained from professional associations, organizations and societies, expert centers, industry records, and national registers;

2. Public records about scientific associated activities like congresses and conferences, publications, scientific articles, guidelines, clinical studies, clinical trials, grants, patents, editorial boards of relevant top journals;

3. In some cases, the information we have, may be directly provided by you;

4. Social media profiles connected to professional activities on LinkedIn, YouTube, and other similar platforms.


Data Processing Overview

The purposes for which we process your personal data are outlined below, along with the corresponding categories of personal data, legal basis, and retention periods. The specific personal data processed in your case may vary depending on which publicly available sources contain your information.

Purpose Categories Legal Basis Retention
Creation,administration,and providing access to your profile for our customers as a part of our Product we offer. Full name, photo, suffix, gender, medical license number, contact data (email, phone number), address, country, job title, professional experience, education and trainings, scientific activity (e.g. publications, conferences), industry payment records. Legitimate interest (GDPR Article 6(1)(f)), where the legitimate interest of Aissel is to connect publicly available information about healthcare professionals to create profiles and inform our customers of possible business relationships consistent with your experience and research interests. Your personal data will be kept for as long as reasonably necessary for the purposes of providing a Product, up to 5 Years.
Management of communication with you, to answer your requests or questions. Full name, contact data (email, phone number),information provided when communicating with Aissel. Legitimate interest (GDPR Article 6(1)(f)), where the legitimate interest of Aissel is to maintain contact with you and to respond to your feedback or notify you of decisions, answers, and other requested or necessary correspondence based on your requests or questions. Your personal data will be kept as reasonably necessary for the purposes of correspondence management and later for 5 years for archival purposes.
Improvement of our Product to ensure that content is presented in the most effective manner. Full name, photo, suffix, gender, medical license number, contact data (email, phone number), address, country, job title, professional experience, education and trainings, scientific activity (e.g. publications, conferences), industry payment records. Legitimate interest (GDPR Article 6(1)(f)), where the legitimate interest of Aissel is to maintain Product as usable, user-friendly, safe and to understand statistics about Product. Your personal data will be kept as reasonably necessary for the purposes of improvement of our Product for a period of 5 Years.
Safeguarding the rights of Aissel. Depending on the content of the case - full name, contact details, data necessary to establish, exercise or defending legal claims of Aissel. Legitimate interest (GDPR Article 6(1)(f)), where the legitimate interest of Aissel is to establish, exercise and defend legal claims. Your personal data will be kept as reasonably necessary for this purposes for a period of 5 Years.

Recipients of Your Personal Data

Aissel will share your personal data with the third party recipients in following ways:

1. Customers – We will share your profile as part of our Product to our customers who have contract with us and who may seek for a business relationships with you consistent with your experience and research interests. Please note, that our customers are sole controllers with their own purposes and goals for processing of your personal data.

2. Service Providers – We will share your personal data with third parties who provide support to us in connection with the Product and help us to improve our services such as IT vendors: AWS Amazon or Microsoft.

3. Regulatory and Governmental Authorities – We will share your personal data with regulatory and governmental authorities when required to do so by law. Any such request will be assessed for its validity and legality prior to the transfer of any personal data.


Data Security and Transfers Outside EU/EEA

Aissel is concerned about the security of your personal data. To protect your privacy and to safeguard against unauthorized access, disclosure, alteration, loss, misuse, or destruction of your information, we implemented appropriate physical, electronic, and organizational measures. Whenever your personal data will be transferred outside the EU/EEA to a so called “non-adequate country”, we ensure an adequate level of data protection in accordance with the requirements of EU data protection legislation, including as required, Standard Contractual Clauses (SCCs) Module 1 (Controller to Controller) and Module 2 (Controller to Processor) adopted by the European Commission together with Data Transfer Impact Assessments (TIAs). SCCs are the agreements between Aissel and any third party from a non-adequate country which requires the third party to treat your personal data in accordance with EU data protection laws. TIAs are the documents that evaluate the level of the personal data protection in the non-adequate destination countries and determine if additional safeguards are necessary.

Details of these security measures can be provided by contacting us as per the “Contact” section below.


Your Rights Relating to Personal Data

Under GDPR, you have certain rights regarding to the processing of your personal data. You have a right to:

  1. Request access to your personal data – this enables you to know what personal data we process about you and receive a copy of it;
  2. Request an update to your personal data – this enables you to update inaccurate or incomplete personal data we hold about you;
  3. Request the deletion of your personal data – under certain circumstances described in Article 17 of GDPR, this enables you to delete personal data we hold about you;
  4. Object to the processing of your personal data – under certain circumstances described in Article 21 of GDPR, whenever the processing is based on legitimate interest, you can object to the processing of your personal data;
  5. Request restriction of processing your personal data – under certain circumstances described in Article 18 of GDPR, this enables you to ask us to suspend the processing of your personal data;
  6. Request the transfer of your personal data – this enables you to request that some of your personal data be provided to you, or to another data controller in a structured, commonly used and machine-readable format;
  7. Lodge a complaint with a supervisory authority – you have the right to lodge a complaint with the applicable supervisory authority, you can find necessary contact details here:
https://www.edpb.europa.eu/about-edpb/about-edpb/members_en

If you want to exercise any right, please contact us in a way outlined below in the “Contact” section. To protect your privacy and security, we may take reasonable steps to verify your identity before processing your request.


Automated Decision Making

Personal data covered by this Notice will not be used in the context of taking any automated decisions including profiling, which produces legal effects concerning you or significantly affects you in a similar way.


Changes to the Notice

We may update this Notice from time to time to reflect any changes to the way in which we process your personal data or changing legal requirements. We will promptly provide the updated version so you are always informed. The revised Privacy Policy will be effective when provided.


Contact

If you have any concerns, comments, or questions regarding the processing of your personal data and the content of this Notice, need further information on personal data protection or you want to exercise your rights relating to personal data, please do not hesitate to contact us. See below for contact details:

Data Privacy Officer Email :