Healthcare Professional Privacy Notice

The categories of personal information that we collect, and use, may include:

• Identification information, including your full name, date of birth, tax number and other government identification numbers.
• Contact information, including your e-mail addresses, telephone numbers, mailing addresses and social media profile.
• Profile information, including your title, education, languages spoken, country of residence, department, company, or organization that you work for or that you collaborate with, age and gender, communication preferences, use of both Gilead and non-Gilead products and related information and the customer segment that you have been attributed to.
• Professional information and experience, including professional role, professional credentials and history, medical specialty, license information, work experience, membership of associations and boards, medical and scientific opinions given, and publications drafted.
• Financial information, including details related to your compensation and transfers of value from us (or those acting on our behalf) to you or the organization that you work for.
• Due diligence related information, including disciplinary history, prior litigation, regulatory proceedings, and circumstances which may create a conflict of interest.
• Interaction and communication information, including information in and about e-mails, messages, telephone calls, responses to surveys that you participate in, meetings and other activities, your use of our digital channels and services, and any comments you may make about us, our business and therapeutic areas we specialize in on public domains (such as social media sites).
• Project and Event information, including information on type of projects and events you participate in, such as date(s), location(s) and topics.
• Picture, video, and audio material, which includes video footage of you, your picture or voice, photographs and video and audio recordings in connection with webinars or virtual meetings in which you participate, whether or not sponsored by Gilead.
• Travel-related information, including your national ID number, passport number, driver’s license number, tax identification number and travel preferences.
• Technical information derived from tracking technologies, including information about the device you use to access our websites, apps and systems, information about how you use our websites and digital content (such as downloads, pages visited, access time), device location, IP address and other online type of identifiers, as well as pixels used to track your engagement with emails. For more information about our use of cookies and other tracking technologies please read our cookie statement at www.gilead.be/cookieverklaring.

We collect personal information from:

• You, when you interact with our staff, enter into a collaboration agreement with Gilead, register to receive marketing material and/or other information from us, attend our online and in-person meetings and events, use our websites, apps and systems, share adverse events and medical information, participate in our surveys, share or use your social media profile to contact us, or request support and information.
  It is your choice whether you provide personal information when we ask you for it. If you decide not to give us your personal information, it may restrict our relationship with you, as we may not be able to completely deliver the services that you require or perform our contractual obligations.
• The organization that you work for, for example from your organization’s website or other communications material.
• Event and travel management agencies, for example in the context of your participation at conferences and symposia that we arrange or sponsor
• Publicly available sources, for example websites, official registers, directories of HCPs, and professional and other social media platforms (including by social media listening tools, used to monitor what HCPs publish about us, our business, products, and therapeutic areas we specialize in).
• Your patients, where they have told us you are their HCP.
• Third Parties, such as data companies who provide information services in the healthcare sector to companies like ours and/or which maintain databases with HCPs’ personal information, including relating to clinical trials you participated in, publications you made, or congresses you attended.
• Our Affiliates that have previously collected your personal information and share your personal information with us.

We may combine and use your personal information, collected from different sources, in different ways depending on your interactions with us. Examples of how we use your personal information include:

Learning more about you

Like all pharmaceutical companies, it is important that we have an understanding of the professional profile of HCPs operating in our areas of research interest. In this respect, we may process your personal information in order to learn more about you and in particular to:

• Maintain a database to identify and engage with you based on your professional expertise and opinions, and our interactions.
• Assess your suitability for our projects based on your areas of expertise and by carrying out background checks to ensure we are not precluded from working with you.
• Review your usage of our websites and/or apps and analyze the previous website you visited, the links you clicked, pages you visited and other usage and browsing activity to understand your interests and preferences to improve our relationship with you by personalizing your experience and to inform our communications with you.
• Review your attendance at events we organize or sponsor, to understand your interest in particular areas of research or clinical practice and to use this information to inform our communications with you.
• Analyze how you engage with communications we send to you (e.g., through the use of email pixels or other similar technology to determine if communications are opened) so that we can measure and improve the effectiveness of our marketing and other campaigns and to inform our future communications with you.
• Understand public perception of our products by analyzing statements, including information published by you about us, our products, business and therapeutic areas we specialize in on external sources such as social media platforms.

Providing you with financial support

If we provide financial support to you to attend meetings or if we look to engage you to provide services to us, we may use your personal information to:

• Determine your suitability to receive our support or to provide services, including your expertise and other background checks to ensure we are not precluded from working with you
• Pay you for services you have provided and reimburse you for expenses related to those services or, where agreed in advance, in relation to attending Gilead or third-party meetings.
• Manage and assess applications by your organization or by you for grants, fellowship or travel support, including eligibility to receive support and considering potential conflicts of interest.

Engaging with you

We pro-actively communicate with HCPs to talk about research opportunities, for product marketing, and to promote events. You may also choose to get in touch with us for various reasons. Specific purposes for which we may use your personal information to:

• Send you product information, tell you about related services, and provide you with administrative information (e.g., sending email with event details where you have registered to attend).
• Arrange meetings, seminars, medical education events and similar activities.
• Interact with you through online digital advisory forums.
• Ask you to complete a survey to give feedback, which we use to make improvements to our products and services.
• Respond to and handling your questions or requests.

Carrying out research

We work with HCPs as investigators and research partners in the context of our clinical and scientific research activities. We may use your personal information to:

• Recruit you as an investigator for a research study.
• Arrange meetings, seminars, medical education events and similar activities.
• Conduct clinical trials and other research studies. .
• Undertake market research to obtain insight about a disease area in which Gilead is interested, in order to improve our understanding of the pharmaceutical industry, and to develop and tailor our business and services. Your responses to market research questions may be analyzed on an aggregated or individual level.

Other general business purposes

In addition to the activities above, we may need to use your personal information for general business purposes, including to:

• Plan for and implement business restructuring.
• Complete management reporting, analytics and metrics.
• Conducting training and ensuring quality control.
• Analyzing or predicting your preferences to identify general trends to develop, improve or modify our products, services and business activities
• Process orders for cell therapy products.

Legal compliance and claims

• Monitoring the safety of our products including those related to adverse events, product complaints and safety.
• Defending and exercising legal claims and rights.
• Conducting training and ensuring quality control.
• Detecting, preventing, and investigating misconduct.
• Responding to requests from competent public authorities such as data protection authorities and other regulators.
• Fulfilling other legal obligations and regulatory requirements.

Transparency reporting

• For transparency reporting regarding the amount of direct and indirect payments, whether in cash, in kind or otherwise, made to HCPs or for their benefit, we use your personal information: (i) to comply with national laws; ii) for our legitimate interests; or (iii) with your consent..

Where required by applicable law, we rely on one or more of the following legal grounds to process your personal information:

Performance of a contract

We may collect and use your personal information to:

• take steps to enter into a contract with you (such as collecting your name, contact details and area of specialism, providing you with financial support, and carrying out research activities under a contract with you), and
• perform our obligations under a contract with you (such as making payments to you).

In accordance with the scope of the contract, we may also use images, audio material and video recordings of you, for example in connection with webinars or digital meetings that we arrange.

Legitimate interest

We may use your personal information where necessary for our legitimate interests, including: We may use your personal information where necessary for our legitimate interests, including:

• Sending direct marketing materials to you, where we are not required to rely on your consent (we provide a way to opt out of marketing communications).
• Planning and improving our business activities (e.g., conducting mergers and acquisitions and planning company strategy).
• Conducting training and gathering feedback for ensuring quality control.
• Verifying your eligibility to access certain products, services and data that may be provided only to licensed HCPs or otherwise conducting background checks to ensure we are not precluded from working with you.
• Analyzing your interactions with Gilead (e.g., your participation in Gilead events, your interaction with Gilead websites, emails and telephone marketing and your professional activities) in order to tailor our communications with you according to your perceived preferences and interests. For more information see ‘Profiling’ below.
• Analyzing your contributions to HCP market research in order to develop, improve or modify our products, services and business activities.
• Interacting with you through online digital advisory forums.
• Responding to and handling your queries or requests.
• Maintaining a database to identify and engage with you based on your professional expertise and opinions, and where applicable, our interactions.
• Contacting you to request input on surveys relating to our products or services.
• Supplying cell therapy products for your patients.

Consent

Depending on the jurisdiction, we may need your consent to use your personal information, and we will obtain your consent where required by law, for example where you share sensitive information about yourself (such as dietary requirements or health information) and when we send you direct e-marketing communications and promotional material. We may also need to rely on consent to collect information through tracking technologies, such as cookies, on our websites.

Compliance with law or regulations

We may use your personal information as necessary to comply with applicable law/regulations (such as responding to adverse events, anti-corruption, transparency reporting, money laundering, accounting, financial and data retention obligations).

To protect the vital interests of you or another person

This covers the use of your personal information in emergency situations.

If you wish to know more about our use of your personal information, its purposes and the legal grounds on which they are based, please contact us by e-mailing [email protected].

We collect information from our own interactions with HCPs, as well as from third parties (such as publicly available and commercial HCP databases, publications in scientific media and / or on social media accounts and from third party organizers of Gilead sponsored events), and combine such information in order to understand areas of professional interest (including interest in Gilead products, our business and therapeutic areas we specialize in ) and the communication preferences of the HCPs we work with (or are interested in working with). We use this information in order to make automated recommendations to our sales teams regarding the most effective and relevant ways to engage with HCPs

We share your personal information with different recipients:

• Affiliates, within the Gilead group of companies, for example to manage the customer relationship and to arrange meetings, seminars, events and similar activities.
• The organization that you work for, for example to manage our customer relationship with you and with your employer.
• Service providers, to assist and support us to provide services and assistance to you (such as meeting and events coordinators marketing agencies, web hosting and storage service providers)
• Individuals that participate in the same activity as you, for example in connection with events that you participate in.
• The public, when we report value transfers in connection with transparency reporting.
• Other recipients, including public authorities, government bodies and regulators, professional advisors, such as auditors and accountants, lawyers, and insurance companies for legal purposes, for example to manage, defend or exercise legal claims and rights in connection with a court dispute.
• In the event of any reorganization, merger, sale, or transfer of any portion of our business, your personal information may be transferred to the parties involved in accordance with applicable law.

We retain your personal information for no longer than is necessary for the purposes for which it has been collected and in accordance with any specific retention periods required by law. Our retention periods are based on the nature of our relationship with you, legal or regulatory requirements and business needs.

We take appropriate measures to protect personal information that are consistent with applicable privacy and data security laws and regulations, including requiring service providers to use safeguards to protect the confidentiality and security of personal information.

Due to the global nature of Gilead’s operations, your personal information may be disclosed throughout the Gilead affiliates, and/or to Gilead service providers, to fulfil the purposes described in this HCP Privacy Notice.

This may include transfer to and storage of personal information in countries other than where you are based, for the purposes and in the manner described in this HCP Privacy Notice, including to servers and other storage facilities in the United States, where Gilead is headquartered. To the extent that personal information is sent outside of your country, it is subject to the laws of the country in which it is, and may be subject to disclosure to the governments, courts, or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country, which may not provide an equivalent level of protection to the laws of your home country.

Gilead implements safeguards to protect personal information, such as entering into standard data protection clauses, to protect and maintain the security and confidentiality of your personal information. To find out more about these safeguards please contact us by e-mailing [email protected].

We will take steps in accordance with applicable laws to keep your personal information accurate, complete and up to date. Below we describe some of the rights that you may have, depending on your location or where you are a resident. These rights are subject to certain exceptions depending on local law. If you wish to exercise your rights or would like more information about these or other rights, please contact us by e-mailing [email protected].

You may have the right to:

• Request information about how we use your personal information and to be provided with copies of your personal information that is held by Gilead.
• Withdraw your consent, if you have given consent for the processing of your personal information, including for purposes of direct marketing.
• Ask us to correct your personal information that you believe is inaccurate or incomplete.
• Request that we restrict how we use your personal information.
• Object to our use of your personal information, including profiling.
• Request that we delete your personal information in certain circumstances.
• Ask us to move your personal information to you or another organization.
• Lodge a complaint with a local data protection authority.

If you have any questions in relation to our use of your personal information, please contact us by emailing [email protected].

Gilead also has an appointed European Data Protection Officer, whom you can contact by emailing [email protected].

You can also find information about how Gilead processes personal information here:
www.gilead.be/privacyverklaring. The Gilead Privacy Statement also includes a number of supplements where you can find additional information relating to your region, country or state, when applicable.