General Enquirer Privacy Notice

 
 

We take privacy seriously. This notice is intended for individuals who are business partners or work for business partners, visit our premises, use one of our websites or otherwise interact with us electronically, by phone or in person.

This notice tells you who we are, what information about you we collect, and what we do with it. We will use information about you only in accordance with applicable data protection laws.

For anything not contemplated by this notice, we may issue a supplemental notice. You should read any supplemental notice in conjunction with this notice.

In the section introduced as “What rights and options do you have?”, you can also find information about your rights.
 
 
Who are we?

This privacy notice is issued by the Vectura Fertin Pharma group of companies, which is made up of a number of companies or “affiliates” as set out at the end of this notice.

“We” (or “us” or “our”) refers to Vectura Fertin Pharma Inc. and its affiliates.
 
 
How do we collect information about you?

We may collect information about you in various ways.

  • You may provide us with information directly (e.g. when you visit our premises and demonstrate your identity; sign a contract; register to receive our press releases or e-mail alerts; fill in a form; correspond with us, meet one of our employees or make a call to us).

  • We may collect information automatically (e.g. when you use a company app or website; CCTV at building entrances, exits and loading bays; when you use company systems and company-issued software and devices such as a laptop or mobile phone).

  • We may acquire information from third parties (e.g. your employer, your representative or publicly-available sources, such as on a company website, internet searches, business information agencies, or on social media platforms).

In this notice, we refer to all the methods by which you are in contact with us as “touchpoints”. Touchpoints include both physical (for example, offices and events) and digital (for example, apps and websites).

We may collect information about you automatically through the use of cookies and similar tracking technologies on digital touchpoints. The specific cookies and technologies used will depend on the touchpoint in question. To learn about the cookies and similar technologies used on a touchpoint, including how you can accept or refuse cookies, please see the cookie notice made available on or through that touchpoint.

We may also collect information in other contexts made apparent to you at the time.

 
 
What information about you do we collect or create?

We may collect various types of information about you:

  • information necessary to manage and administer our relationship with you, your employer or representative and to run our business, including to meet our legal and regulatory obligations 

  • information necessary to purchase products and services

  • information necessary to provide you with press releases or e-mail alerts

  • information you give us in contracts, forms or surveys

  • information about your visits to our offices and attendance at events 

  • information for building access control systems;

  • biometric data for identification purposes (for building access controls, or access to IT devices);

  • information you give us in calls you make to us, meetings you have with our employees, or electronic communications you send to us

  • information about your visits to other touchpoints

  • information about your preferences and interests

  • information necessary to verify your age, identity and authority to act on behalf of your employer if applicable

  • information about your publicly known views, opinions, and decisions which may affect public policy and other issues which relate to us

  • information submitted to us when using information systems that we operate

  • automated records of your use of our information systems, including company-issued devices

 
 
For what purposes do we use information about you, and on what legal basis?

In this section, we describe the purposes for which we use personal information.

Depending on the nature of our relationship with you, we may use information about you for the following purposes:

  • To comply with regulatory obligations, such as verifying your age and identity, undertaking ‘know your supplier’ checks and managing our contractual relationship with you or your employer

  • Legal compliance, such as retaining and using your records in relation to any anticipated disputes, for the purposes of obtaining advice from our lawyers and other advisers

  • To purchase products or services from you or your employer, including contacting you to manage our relationship, obtain sales-related services and to pay you for goods, services and expenses (where appropriate)

  • To sell our products to you, including fulfilling your orders, processing your payments

  • To provide sales-related services to you, including dealing with your inquiries and requests, and providing warranty services

  • To inform you of updates, promotions, events and manage related aspects of our relationship, including administering loyalty programs, product improvement, market research, developing marketing strategies, administering marketing campaigns, and customizing your experiences at events

  • To support all the above, including administering your or your employer’s accounts

  • Enabling you to use our touchpoints, corresponding with you, managing your appointments with us, customizing your experiences of our touchpoints, administration and troubleshooting, general record keeping, fraud prevention and managing your access to any systems to which we have granted you access

  • For business analytics and improvements, including improving our products, offices, processes and events, and the information, systems and devices

  • To enable and administer your use of our systems, company-issued software, our devices and our information

  • To monitor your use of our systems and devices to ensure appropriate use

  • To maintain the security of our systems, devices, information and buildings

  • To understand your views, opinions, decisions, and how they may affect public policy and other issues which relate to the company

  • To provide you with, and customise your experiences of, press releases and e-mail alerts to which you have subscribed

  • For other purposes that we notify you of, or will be clear from the context, at the point information about you is first collected

 

The legal basis for our use of information about you is one of the following (which we explain in more detail in the table below):

  • compliance with a legal obligation to which we are subject; 

  • the performance of a contract to which you are a party; 

  • a legitimate business interest that is not overridden by interests you have to protect the information; 

  • where none of the above applies, or where law requires it, your consent (which we will ask for before we process the information).

The purposes for which we use information about you and legal basis for use are:

 

Purpose

Legal basis for processing

Comply with regulatory obligations

• verify your age, identity and business partner status

• tax and business accounting obligations

• checks related to “know your supplier”, trade sanctions and background checks

• health and safety management

• legal and regulatory disclosure requests

• conflicts of interest

• recording of timesheets and invoices, to the extent that you act as an external advisor

• keeping contracts and associated documents in which you may be referred to

• investigation of reported allegations of misconduct

We use it because it is necessary for us to comply with a legal obligation to run our business in a compliant way or, in countries where there is no such legal obligation, because we have a legitimate business interest to run our business in accordance with good practice requirements that is not overridden by your interests, rights and freedoms to protect information about you.

Purchase products and services

• contact you in the course of your or your employer’s providing us with products or services

• administration of the account held by us with you or your employer

• process payments

• relationship management

• monitoring of your compliance with our agreement, our policies and internal programs

• investigation of non-compliance with our agreement, policies and internal programs, issues and incidents

We use it in relation to the performance of our contract with you or your employer as a purchaser of your or your employer’s products or services or, where there is no such obligation, we use it because we have a legitimate business interest to run our business, contact you in relation to the products or services we are receiving from you or your employer, to process payments, manage our relationship with you or your employer and monitor compliance with our agreement, policies and programs that is not overridden by your interests, rights and freedoms to protect information about you.

Sell our products

• fulfil your orders (including sending receipts)

• process your payments

• provide warranty services

We use it to discharge our contractual obligations to you or your employer as a buyer of our products.

Provide sales-related services, business promotion and relationship management

• deal with your inquiries and requests

• correspond with you

• general administration and troubleshooting

• relationship management

• inform you of relevant updates, promotions and events

• understand your preferences (such as what products or events may interest you or may be better tailored to your needs)

• invite you to participate in, and administer, surveys or market research campaigns

• for market research

• administer marketing campaigns

• customize your experience of touchpoints

• provide you with information about our promotions, products and services, events

• provide you with, and customise your experiences of, press releases and e-mail alerts to which you have subscribed

We use it because we have a legitimate business interest in providing sales-related services to you or your employer, to manage our relationship and tell you about our business, products and events, to operate our touchpoints, and to customize your experiences that is not overridden by your interests, rights and freedoms to protect information about you.

Business administration 

• general organizational management and business record keeping

• contractor lifecycle management

• visitor administration and record keeping

• administering and running events, training and compliance programmes

• correspondence in relation to our relationship with you or your employer, including to deal with your inquiries and requests

• IT systems development, implementation, operation and maintenance

• maintaining the security of systems, devices, information and buildings

• the operation of contact databases and collaboration tools

• international assignments and travel

• operating a safe work environment

• maintaining the security and safety of our staff, customers, suppliers, visitors and the property of each

We use it because we have a legitimate business interest to run our business, manage our relationship with you and maintaining the security and integrity of our buildings, information and IT systems that is not overridden by your interests, rights and freedoms to restrict use of information about you.

Security and systems monitoring

• authentication and access controls and logs, where applicable

• monitoring of systems, devices, internet and e-mail to which you are granted access

• monitoring of access to our premises, deliveries to our affiliates, and security-related processes at our premises

• enabling and administering your use of our systems, company-issued software, company devices and company information; monitoring your use of these, including to ensure appropriate use and appropriate handling of company information

• maintaining the security of systems, devices and buildings

• video (CCTV) and audio monitoring

We use it because we have a legitimate business interest in ensuring the confidentiality, integrity and security of our physical and digital infrastructure, information and premises that is not overridden by your interests, rights and freedoms to protect information about you.

Support for all the above purposes

• administering your accounts

• enabling you to use our PMI touchpoints

• corresponding with you

• enhancing your experiences

• administration and troubleshooting

We use it on the grounds that correspond to the purpose for using the information that we are supporting. For example, where we administer your account to support a purchase, we use the information to discharge our contractual obligations to you as a buyer of our products; where we administer your account to update you on our products, we are supporting business development and so we use it on the grounds that we have a legitimate business interest to market our products that is not overridden by your interests, rights and freedoms to protect information about you.

Business analytics and improvements

• for business analytics and improvements (including for our products, systems, processes, offices, events, digital PMI touchpoints and the devices and information that we provide to you or your employer)

We use it on the grounds that we have a legitimate business interest to analyze and to improve our business performance, our products, systems, processes, offices, training, events, touchpoints and the devices and information we provide, that is not overridden by interests, rights and freedoms to protect your information about you.

Understanding your views, opinions, and decisions

We use it on the grounds that we have a legitimate business interest to monitor and assess the views and decisions of stakeholders and map out the manner in which their views and decisions may affect us and our industry, that is not overridden by interests, rights and freedoms to protect information about you.

Where we do not base our use of information about you on one of the above legal bases, or where law requires it, we will ask for your consent before we process the information (these cases will be clear from the context). We may ask for your explicit consent to process special categories of information about you.

In some instances, we may use information about you in ways that are not described above. Where this is the case, we will provide a supplemental privacy notice that explains such use. You should read any supplemental notice in conjunction with this notice.

 
 
Do we make any automated decisions?
We may make automated decisions on any of the matters set out in this notice (for example, screening and whom to include on a shortlist for purchasing services or products). If we do this, we will draw this to your attention at the time, together with information about the logic involved in the decision, as well as the significance and the envisaged consequences for you of such use of information about you.
 
 
Who do we share your information with, and for what purposes?

We may share information about you with:

  • Companies in the Vectura Fertin Pharma group of companies; its owner, Philip Morris International and its affiliates; 

  • third parties who provide the company or you with products or services; 

  • other third parties, where required or permitted by law (such as regulatory authorities; government departments and professional advisers). 

We share information about you with others only in accordance with applicable laws. Thus, where law requires your consent, we will first ask for it.

 
 
Where might information about you be sent?

When using information as described in this notice, information about you may be transferred either within or outside the country or territory where it was collected, including to a country or territory that may not have equivalent data protection standards. For example, if you are in the European Economic Area (“EEA”), your information may be transferred outside the EEA.

Wherever we transfer personal data to other countries, we will take legally required steps to ensure that appropriate safeguards are in place to protect it. You may contact us for an explanation of the basis on which we have transferred your personal data and, where relevant, to request a copy of the legal safeguards we have put in place.
 
 
How do we protect information about you?
We implement appropriate technical and organisational measures to protect personal information that we hold from unauthorised disclosure, use, alteration or destruction. Where appropriate, we use encryption and other technologies that can assist in securing the information you provide. We also require our service providers to comply with equivalent data privacy and security requirements.
 
 
How long will information about you be kept?
We will retain information about you for the period necessary to fulfil the purposes for which the information was collected in accordance with our internal data retention standards. After that, we will delete it. The period will vary depending on the purposes for which the information was collected. Note that in some circumstances, you have the right to request us to delete the information. Also, we are sometimes legally obliged to retain the information, for example, for tax and accounting purposes.
 
 
What rights and options do you have?

You may have some or all of the following rights in respect of information about you that we hold:

  • request us to give you access to it; 

  • request us to rectify it, update it, or erase it; 

  • request us to restrict our using it, in certain circumstances; 

  • object to our using it, in certain circumstances; 

  • withdraw your consent to our using it; 

  • data portability, in certain circumstances; and

  • lodge a complaint with the supervisory authority in your country (if there is one).

We offer you easy ways to exercise these rights, such as such as “unsubscribe” links or by using the contacts in the paragraph “who should you contact with questions?” at the end of this notice. 

 
 
Who should you contact with questions?

If you have any questions, or wish to exercise any of your rights, you can contact us:

If your country has a data protection authority, you have a right to contact it with any questions or concerns. If the company cannot resolve your questions or concerns, you also have the right to seek judicial remedy before a national court.

 
 
Vectura Fertin Pharma Inc. affiliates
 

Location

Company name

Address

US

Vectura Inc.

677 Washington Blvd, Suite 1100, Stamford, CT 06901

Singapore

Vectura Fertin Pharma Laboratories

50 Science Park Road, The Kendall, Science Park 2 #02-07, Singapore 117406

UK

Vectura Group Ltd

Manning House, 22 Carlisle Place, Westminster, London, SW1P 1JA

Vectura Ltd

One, Prospect West, Chippenham, Wiltshire, SN14 6FH

Vectura Delivery Device Ltd

205 Cambridge Science Park, Milton Road, Cambridge, CB4 0GZ

Vectura Fertin Pharma (UK) Limited

22 Carlisle Place, London, SW1P 1JA

Ireland

Vectura Ireland Ltd

Block 2, Newtown mount Kennedy Business Park, Newtownmountkennedy, Wicklow, A63 XV26

Switzerland

Vectura Fertin Pharma CH, the trading name of Jagotec AG

Messeplatz 10, 4058 Basel

Vectura Fertin Pharma Switzerland SA

Avenue de Rhodanie 50, c/o Philip Morris Products S.A., 1007 Lausanne

Denmark

Fertin Pharma A/S

Dandyvej 19, 7100 Vejle

Vectura Fertin Pharma A/S

Dandyvej 19, 7100 Vejle

India

Fertin Pharma R&D India Private Ltd

Plot No B-22, Ground Floor, TTC Industrial Area, Rabale MIDC, Navi Mumbai 400 708

Fertin India Private Ltd

Plot No. L-10 & L-11, Cuncolim Industrial Estate, Goa 403 703

Vectura Fertin Pharma Private India

Plot No. L-10 & L-11, Cuncolim Industrial Estate, Goa 403 703

Canada

Tab Labs Inc.

19720 94a Ave D107, Langley City, BC V1M 3B7

Cogent International Manufacturing Ltd

400-725 Granville Street, PO Box 10325, Vancouver BC V7Y 1G5
 
 
Changes to this notice

We may update this notice (and any supplemental privacy notice), from time to time. Where the law requires it, we will notify you of the changes; further, where the law requires it, we will also obtain your consent to the changes.

Last modified 3rd of July 2024.