Purpose and scope
Glenmark Life Sciences including its successors, assigns and representatives, its future worldwide subsidiaries and affiliates, if any, (“GLS”) respects your privacy and is committed to protecting your personal data.
Almost all of the jurisdictions in which GLS do business have privacy and data protection laws which govern how organisations can collect, use, and disclose the personal data of their commercial partners and GLS is committed to using any personal data fairly, lawfully and in accordance with all applicable laws.
Use of Personal Data
We may use and disclose personal data for purposes connected to:
The Personal Data that GLS Collects
The personal data that GLS may collect, store and use includes but is not limited to:
Methods of Collecting Personal Data
We may collect this personal data in various ways including the following:
On What Basis Do We Use Your Personal Data?
1. We collect and use your personal data when this is necessary for the performance of a commercial contract (or other similar type of agreement) with Glenmark.
2. We may process some of your personal data when there is a legal requirement or it is in our legitimate interest to do so. This is the case, for example, when we collect and use your personal data to:
What Happens if You Do Not Provide Us with the Personal Data We Request or Ask That We Stop Processing Your Personal Data?
Our ability to perform our obligations derived from the commercial contract (or similar type of agreement) with Glenmark and our ability to comply with our legal and contractual obligations sometimes depend on Glenmark having access to and being able to use certain personal data.
Therefore, depending on the circumstances, if you do not provide us with the personal data we request or if you ask that we stop processing your personal data, we may not be able to perform our contractual obligations (such as paying you for your work) or we may be in breach of one or more legal obligations imposed upon us. In some cases, if we are not allowed to process your personal data, this may result in us being required to terminate our work relationship with you.
Access to Personal Data
Access to your personal data will be given to those who need such access for the purposes listed above or where required by law. These parties include, amongst others, the GLS’ human resources department, relevant business managers and, on limited occasions, members of the Information Technology ("IT"), finance, tax, legal and compliance departments.
Where we are lawfully permitted to do so, we may also transfer or assign personal data to third party business partners who provide products or services to or on behalf of GLS. These third parties may include and are not limited to payroll administrators, benefits administrators, financial consultants and financial services providers, professional advisers, IT systems providers (including enterprise resource planning and cloud-based software providers and consultants), outside counsel, expense claims providers, data management solutions providers, timekeeping solutions providers, hardware providers, travel and mobility companies (including company car management) and general administrative service providers.
GLS will carefully select such third parties and we will enter into appropriate written agreements including a duty of confidentiality. To the extent required, we will ensure that such third parties collect, store, use and disclose your personal information in accordance with applicable local privacy laws. Under certain circumstances, it may be appropriate to allow these third parties to determine the purpose and means of processing of your personal data in order to achieve specified purposes. You should refer to the contents of their respective privacy notices for further information in respect to the manner in which they process your personal data and any queries arising therefrom should be addressed to them directly.
Finally, personal data may be disclosed and transferred to respond to law enforcement requests, court orders, government regulations (including disclosures to tax, social security, and other authorities) or government entities to manage or administer GLS’ financial and tax affairs. We may also disclose personal data to external legal counsel to assist us with the establishment and defence of legal claims or to other third parties also engaged in such legal matters (for example, to the adverse party in court proceedings, to judicial experts or to other stakeholders involved in the claim).
Where is Your Personal Data Stored?
The aforementioned recipients of your personal data and their information storage systems may be located in other countries. Equally, GLS operates globally, and your personal data may be stored and processed by it in multiple jurisdictions.
In the event that we or our partners transfer any personal data, we will ensure that this is only done so in accordance with applicable law, and will require that there is an adequate level of protection for the personal data and that appropriate security, technical and organisational measures are in place.
GLS has policies and procedures in place to ensure that we comply with all applicable laws in the event of a data breach leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data.
For more information about the safeguards relating to cross border personal data transfers or data breach please contact email@example.com
You may have certain rights regarding the personal data that we collect, use and hold about you. These rights may include the following:
Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (as explained below). Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you at the time of your request.
Object to processing of your personal data In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. In such circumstances we may reserve the right to delete your personal data rather than hold it but restrict processing, where our processes are not set up to enable a restriction.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Request information about your personal data. On request, we will disclose to you the categories of personal information Glenmark collected, used or shared about you, which third parties were involved (if any) and why they collected, used or shared that information.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
These rights can be exercised by contacting firstname.lastname@example.org however, please note that in the case of blocking or suppression or further use of personal information, we may need to retain or continue processing certain information, for example for legal or administrative purposes (for example the maintenance of social security records).
We will respond to your request as soon as practically possible and within the timeframes set forth by applicable law.
Retention and Accuracy of Personal Data Collected
GLS intends to keep personal data in its control accurate and up-to-date. We will retain personal data only as long as is necessary to carry out the purposes for which it was obtained and as described in this privacy notice. If there are any changes to your personal data, please notify the business function with whom your GLS relationship is held or the human resources department accordingly. If you inform us of any changes or we otherwise become aware of any factual inaccuracies in your personal data, we will seek to promptly correct such inaccuracies.
GLS has internal retention policies and procedures that build upon the following criteria to determine suitable retention periods for personal data in the context of the abovementioned purposes:
Under certain circumstances, GLS may monitor the use of its information systems including for the purposes of detecting and addressing information security threats or improper use of GLS’ information systems. This may require the processing of certain personal data of individuals related to their use of information systems.
Revisions to this privacy notice
GLS may update this privacy notice from time to time. In order to keep up-to-date with the ways in which Glenmark handles your personal data we request that you visit and review the relevant privacy notices on our privacy portal on a regular basis.
If you have any questions about this privacy notice, how we handle your personal information or wish to exercise any of your rights contained hereunder, please contact us by email at email@example.com
ComplaintsIf you are unhappy with the way in which we have processed your personal data please address any complaint to firstname.lastname@example.org In any case, you also have the right to lodge a complaint with the relevant supervisory authority which can be found at https://pdpecho.com/the-list/