Physician Privacy Notice
1. Personal Data Processing Controller:
Específicos Stendhal, S.A. de C.V., Administración Stendhal, S.A de C.V., Stendhal Colombia S.A.S., Stendhal Costa Rica S.A., Stendhal S.A., Stendhal Panamá, S.A., and Stendhal Américas, S.A., (all of them with the address: Camino a Santa Teresa No. 1040, Mezzanine 1, Col. Jardines en la Montaña, Alcaldía Tlalpan, C.P. 14210, Ciudad de México, México); and Stendhal Perú S.A. (National Taxpayer Registry (RUC, acronym in Spanish) No. 20535696251, with the address: Calle Río de la Plata No. 315, Urbanización Santa Cruz, Distrito de San Isidro, Lima, Perú), hereinafter jointly referred to as "Stendhal", in accordance with the provisions of Local Laws, Regulations, Decrees, Norms, and other applicable provisions on the Protection of Personal Data (hereinafter, “the Law"), hereby discloses this Privacy Notice regarding the processing of your personal data.
2. Collection of Personal Data:
Stendhal collects your personal data for the purposes set forth in this Privacy Notice. In this regard, we state that your data shall be processed and safeguarded based on the principles of lawfulness, quality, consent, information, accuracy, effective updating, purpose, loyalty, confidentiality, proportionality, security, legality, transparency, relevance, legitimacy, and responsibility, enshrined in the applicable Laws, with the exception of any case in which said information is required to be disclosed by court proceedings and/or government authority, in absolute compliance with legal provisions and responsibilities.
Your personal data may be stored and processed in any country where our facilities or service providers may be located, including but not limited to: Guatemala, El Salvador, Panama, Costa Rica, Peru, Ecuador, and the Dominican Republic; it may also be transferred to our affiliates or subsidiaries within the same corporate group. By using our Site or giving your consent (where required by law), you agree to said information being transferred and/or sent to countries other than your country of residence. For this purpose, this document shall be construed as express authorization.
We inform you that your data shall be processed for the duration of the relationship between you and Stendhal.
The data we may require includes, but is not limited to:
Personal information: Full name, address, telephone number(s), email address, mobile phone number, date of birth, age, sex, city, residential status and, where applicable, personal information of one or more family members.
Academic information: Professional license number or registration, specialty license number, or Medical College member/registration number.
Employment information: Employment history or experience, current or previous role or position, work address, information generated during the recruitment, selection, and hiring processes, Curriculum Vitae.
Third-Party information: Identification and contact information of emergency contact(s), identification and contact information of beneficiaries or economic dependents, contact information of personal references, work references, and family members.
3. Main Purposes:
Your personal data may be used for the following main purposes:
Conduct epidemiological research and clinical outcome studies;
Divulge information about medical conditions covered by Stendhal’s portfolio;
Communicate information about Stendhal’s products to healthcare professionals through our representatives, by means of our websites, email, phone calls, postal mail, and other channels, including promotional communications, as applicable;
Organize and participate in symposia, conferences, and other educational and scientific programs;
Conduct market research and satisfaction surveys;
Comply with transparency obligations concerning value transfers, as applicable;
Carry out visits and promote products from Stendhal’s portfolio;
Ask your opinion on medicinal products and medical conditions;
Carry out feasibility analyses;
Deliver scientific, promotional, and educational material;
Request information about the impact and results that our products have had on your patients;
Send key clinical messages about Stendhal’s product portfolio;
Feed and update our database of expert physicians;
Issue certificates of participation in educational events, conferences, colloquia, symposia, conventions, seminars, and presentations, as applicable;
Extend invitations to educational events organized by Stendhal;
Establish communication with you to provide follow-up of product advocacy you may conduct on behalf of Stendhal;
Stendhal may contact you by telephone and/or send you emails and/or use other physical and/or digital means of communication including, but not limited to, instant messaging applications. The foregoing may occur for any situation related to the activities conducted by Stendhal.
Report adverse events per the pharmacovigilance programs for our products.
4. Secondary Purposes:
Provide information, services, products, or events, which include sending promotional material and newsletters from any media belonging to Stendhal, as well as related sponsors and advertisers;
Receive and reply to comments and suggestions;
Receive and reply to complaints, questions, requests, and claims related to Stendhal;
Provide information related to any activity conducted by Stendhal for special events;
Follow up on any relationship that may have been generated between you and Stendhal.
5. Measures to Limit the Use or Disclosure of Your Data:
We hereby inform you that your personal data shall be kept secure under administrative, physical, and technical security measures, which have been implemented in accordance with the Law, with the objective of protecting your data against any damage, loss, alteration, destruction, or unauthorized use, access, and processing, as well as limiting any risk that may arise, to the extent possible.
Sensitive Personal Data Processed by Stendhal:
In addition to the aforementioned personal data, for the purposes set forth in this Privacy Notice Stendhal may also collect and process Sensitive Personal Data of Stendhal users or patients, such as medical information necessary to conduct professional activities, health/medical information, information on union membership, religion, race and/or ethnicity, and marital status. Stendhal collects this information for specific purposes; for example, to provide support according to each person's needs, offer benefits, and/or comply with legal obligations and internal policies. Sensitive Personal Data shall be used exclusively for the purposes set forth in this Privacy Notice and per the provisions of the Law.
In view of the foregoing, by accepting this Privacy Notice, you give consent for the aforementioned Sensitive Personal Data to be processed per the provisions hereof.
6. Exercise of ARCO Rights:
You have the right to know what personal data we have collected from you and the purposes and conditions of use thereof (Access). Likewise, you have the right to request rectification of your personal data in case it is outdated, inaccurate, incorrect, or incomplete (Rectification); request its elimination from our records or databases when you consider that it is not being used in accordance with the principles, duties, and obligations provided by the Law (Cancellation); and oppose the use of your personal data for specific purposes (Opposition).
To exercise any of these rights in Mexico, you must submit a request by contacting the Legal Department at datos.personales@stendhalpharma.com or at the address: Camino a Santa Teresa No. 1040, Mezzanine 1, Col. Jardines en la Montaña, Alcaldía Tlalpan, C.P. 14210, Ciudad de México, México. Your request must state: (i) the name of the Rightsholder and an address or other means through which we can provide a response to your request, (ii) documents that prove the identity or, as applicable, the legal representation of the Rightsholder, (iii) a clear and precise description of the personal data over which any of the aforementioned rights are to be exercised, and (iv) any other information or document that may contribute to locating the personal data in question.
We shall respond to your request within a maximum of 20 (twenty) business days. The personal data that you request from us may be reproduced and delivered in a digital file, as applicable.
In Costa Rica, Stendhal has a period of 5 (five) business days from the date on which your request was received to inform you by email or at the address provided in your request of the decision taken and act upon said decision, if applicable. The aforementioned period may be extended once for an equal amount of time, provided that it is justified by the circumstances of the case.
In Peru, Stendhal has a period of 20 (twenty) calendar days to respond to requests regarding the right of access and 10 (ten) business days to respond to requests regarding the rights of rectification, cancellation, and opposition. If Stendhal informs you that you have failed to meet the minimum requirements for submitting your request, you must rectify this situation within 5 (five) business days of receiving such notice; otherwise, your request shall be deemed not submitted and voided. If Stendhal informs you that your request requires additional information in order to be processed, you must provide said information within 10 (ten) business of receiving such notification; otherwise, your request shall be deemed not submitted and voided. The aforementioned period may be extended once for an equal amount of time, provided that it is justified by the circumstances of the case.
In the Dominican Republic, Stendhal has a period of 10 (ten) business days from the date on which your request was received to inform you by email or at the address provided in your request of the decision taken; in the event that the information in question comes from a public entity or institution, Stendhal shall have an additional period of 5 (five) business days for a total of 15 (fifteen) business days from the date of notification to act upon said decision. The rights of the Rightsholder may be denied based on matters of national security, public order and safety, or the protection of the rights and interests of third parties, per the provisions of the Law.
In Ecuador, Stendhal has a period of 15 (fifteen) calendar days from the date on which your request was received to inform you by email or at the address provided in your request of the decision taken.
You may revoke the consent that you may have granted us, as applicable, for the processing of your personal data. To that effect, you must submit a request through the aforementioned means. However, it is important that you bear in mind that we may not always be able to fulfill your request or immediately terminate use of your data, as it is possible that we may be legally required to continue processing your personal data. Likewise, you must bear in mind that, for the main purposes set forth herein, revoking your consent means that we cannot continue to provide the goods or services you requested from us, and it may cause the termination of your relationship with us.
Rightsholders may opt out of all contact, including email, instant messaging, facsimile, and telephone; for this purpose, we keep "no call" and "no correspondence" lists.
7. Transfer of Data:
Personal Data collected by Stendhal shall be used for the purposes for which it was provided, as set forth above, and shall only be transferred to Stendhal’s affiliates or subsidiaries and each of the departments within them, as well as to third parties hired by Stendhal to process and analyze said information. The recipient of your information shall be appointed by Stendhal and required to treat your personal data with the same levels of security used by us and as required by the Law.
Stendhal shall never request data that may identify a patient; therefore, physicians undertake to never share any identifiable data, and all patient data must be dissociated from their identity.
8. Security:
We only collect information that we consider reasonably necessary to serve the legitimate interests of our business and to fulfill our legal obligations. We protect Rightsholders and their disclosed information using industry protection standards as required by the Law. Regardless of whether there is "guaranteed online or offline security,” we shall make every commercially reasonable effort to ensure that the collection of information carried out by us complies with all applicable Laws.
Currently, each means of collection of information, including digital applications, uses a variety of security measures intended to protect the information and prevent unauthorized use by users within and outside the company, including administrative, technical, and physical security measures per the provisions of the Law. This protects confidential information, such as confidential numbers, online applications, and financial information, against loss, damage, misuse, interception, or sabotage.
Our practices regarding communication systems, software, and physical and digital databases are designed to assist us in maintaining the authenticity, integrity, and confidentiality of said information. It is important to state that, regardless of us using all the means necessary to ensure the security of the information when it is transmitted through third parties (service providers), we cannot by any means guarantee the security of the information during such transmissions.
11. What we will not do with the information:
Sell, lease, or otherwise commercialize the information to third parties outside the companies controlled by and/or related to Stendhal (with the exception of agreements entered into while the companies in question were related to Stendhal and later came out of Stendhal’s control), or allow our affiliates to sell or lease the information to third parties previously or currently not controlled by Stendhal;
Function as an evaluation agency for services and activities involving the Rightsholder, nor provide any type of information related to the financial situation, purchasing power, personality, character, reputation, personal characteristics, or lifestyle of the Rightsholder to any such evaluation agencies;
Disclose, reproduce, send, share, or show the data or reports derived therefrom to third parties not associated to Stendhal, especially through any means of mass communication such as print, television, radio, or any other form of broadcasting or publishing, digital or otherwise.
11. Changes to this Privacy Notice:
This Privacy Notice may be amended in the future. In any case, any and all modifications shall be made known to you by delivering a new Privacy Notice or indicating where you may consult it.
11. Contact Information:
For any matter related to this Privacy Notice and regarding your personal data, you may contact us at datos.personales@stendhalpharma.com or at the address: Camino a Santa Teresa No. 1040, Mezzanine 1, Col. Jardines en la Montaña, Alcaldía Tlalpan, C.P. 14210, Ciudad de México, México, for the attention of the Legal Department; or call +52 (55) 2000 6630.
Last updated: May 2024
