私隱政策

Website Privacy Policy

1. General

Boehringer Ingelheim (HK) Limited ("We" or “us”) are committed to protecting and respecting your privacy.

This Privacy Policy (together with our Terms of Use as set out in our Terms of Use (please hyperlink to Term of Use) and any other documents referred to in it) applies to your use of:

• The https://www.sugar2control.com (“Website” or “Site”).
• Any of the services accessible through the Site. 

In this Privacy Policy, the terms “personal data”, “processing”, “data user” and “data processor” shall have the meaning ascribed to them in the Personal Data (Privacy) Ordinance (Cap 486 of Laws of Hong Kong).

This Privacy Policy sets out the basis on which any personal data We collect from you, or that you provide to us, or generated by us, will be processed by us.  Please read the following carefully to understand our views and practices regarding personal data and how We will treat it. By providing us with information about you and/or by continuing to use our Website, you are accepting the practices described in this Privacy Policy. 

This Privacy Policy applies to (including, but not limited to) the sharing by you of information; for example, information relating to a product, service, business or brand via our Site, to a third party or parties, including (but not limited to) a friend, acquaintance or contact.

Our Site is not intended for minors under 18 years of age.  No one under the age of 18 may provide personal data to or through the Website.  We do not knowingly collect personal data from minors under 18.  If you are under 18, please do not create an account or send us any information about you.

The data user is Boehringer Ingelheim (HK) Limited, of Suites 1504-9, Great Eagle Centre, 23 Harbour Road, Wanchai, Hong Kong.  

2. Personal data We may collect from you

We may collect and process the following personal data about you: 

Personal data you give us. You may give us information about you by filling in forms on our Site or registering on our Site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our Site, subscribe to receiving emails from us, subscribe to receive information from us, search for a product, report an adverse event or provide pharmacovigilance-related information, participate in discussion boards or other social media functions on our Site, enter a competition, promotion or survey, and when you report a problem with our Site. The information you give us may include your name, address, e-mail address and phone number and incidents experienced with any product that We manufacture or sell. 

Personal data We collect about you. With regard to each of your visits to our Site We may automatically collect the following information:

• Additional information – if you provide additional information (such as information regarding your professional standing) in order to access restricted information, then We will collect that information.
• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. 
• Information that you provide to us for the purpose of registering with us and allowing us to send you email notifications and/or promotional information.
• Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number. 

Personal data We receive from other sources. We may receive information about you if you use any of the other websites We operate or the other services We provide. (In this case We will have informed you when We collected that data that it may be shared internally and combined with data collected on this Site.) We are also working closely with third parties (including, for example, business partners, sub-contractors in technical and delivery services, advertising networks, analytics providers, search information providers) and may receive personal data about you from them. We may also collect personal data regarding you from someone you duly authorize to act on your behalf.

From time to time you may be able to visit the Website and deal with us anonymously or by pseudonym.  However, please be aware that if you do not provide us with certain information that We require, We may not be able to provide you with particular services that you seek.

3. Cookies

We use cookies and other similar technologies such as pixel tags, embeddable scripts and local storage. Cookies are small text files that may be places on your computer or other device by websites when you visit them. Cookies enable us to recognize your device on a subsequent visit by that device to our Website and allow us to deliver a more personalized experience by providing information to us. Cookies are essential for some website functions and these functions will not work in the absence of those cookies.  You can use the browser privacy functions to clear the cookies already on your device or to block cookies in the future by altering the browser privacy settings.  However, please note that this may cause some of the functionality of the Website not to work correctly. If you continue to use our Website you accept the use of cookies.  For detailed information on the cookies We use and the purposes for which We use them see our Cookie Policy (please hyperlink to Cookies Policy).

4. Uses made of the personal data 

We use information held about you in the following ways:

Purposes for processing.  We may process personal data regarding you for a number of purposes (including but not limited to): staff administration, advertising; marketing and public relations (please see the paragraph entitled “Marketing” below for further information); accounts and records; consultancy and advisory services; research; trading/sharing in personal information; crime prevention; health administration and services; administration of membership records; information and databank administration; education and journalism; media collecting, monitoring, researching, and evaluating information from healthcare providers and patients on the adverse effects of medicines.

Personal data you give to us. We will use this information:

• to provide you with the information, products and services that you request from us;
• to provide you with information about other  products and services We offer that are similar to those that you have already purchased or enquired about;
• to provide you, or permit selected third parties to provide you, with information about products and services We feel may interest you. Where We permit selected third parties to use personal data regarding you, We (or they) will contact you by electronic means only if you have consented to this;
• to notify you about changes to our website;
• to ensure that content from our Site is presented in the most effective manner for you and for your computer. 

Personal data We collect about you. We will use this information:

• to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our Site to ensure that content is presented in the most effective manner for you and for your computer; 
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our Site safe and secure;
• to measure or understand the effectiveness of advertising We serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our Site about products or services that may interest you or them.

Personal data We receive from other sources. We may combine this information with information you give to us and information We collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information We receive).

5. Marketing

We will only send you marketing material if you consent.   We will only disclose personal data to third parties (including any member of group) for use in marketing if you further consent. 

When We send you marketing material, We may monitor whether or not you open and/or click on the material that We send you.  

If you have consented to receive marketing material from us, you have the right at any time to ask us not to process personal data relating to you for marketing purposes. If you wish to exercise this right, please contact us at webmaster@hon.boehringer-ingelheim.com.

6. Disclosure of personal data 

We may disclose personal data to third parties in certain circumstances including (but not limited to) the following:

• to fulfil the purposes for which you provided information regarding you;
• our professional advisers, including lawyers, accountants, tax advisors and auditors;
• regulatory or government bodies including to monitor the effect of medicines or medical devices and also to resolve complaints or disputes both internally and externally or to comply with any investigation of those bodies;
• if We sell or buy any business or assets, in which case We will disclose personal data regarding you to the prospective seller or buyer of such business or assets; 
• if We are under a duty to disclose or share personal data regarding you in order to comply with any legal or regulatory obligation or request, or in order to enforce or apply our terms of use or to protect the rights, property, or safety of Boehringer Ingelheim (HK) Limited, our customers, or others;  
• third parties to whom We outsource services such as data hosting, analytics, marketing and Site development and maintenance; 
• to business partners, suppliers and sub-contractors for the performance of any services We may provide for you or any interactions We may have with you as part of your use of the website, including the running and hosting of the website; and/or
• to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in the Companies Ordinance (Cap 622 of Laws of Hong Kong); and/or
• for any other purposes that you would reasonably expect.

Before We disclose any personal data to a third party, We take steps to ensure that the third party will protect personal data regarding you in accordance with applicable privacy laws and in a manner consistent with this Privacy Policy. Third parties are required to restrict their use of this information to the purpose for which the information was provided.

We may transfer personal data regarding you  to overseas recipients for business purposes and operational, support and continuity purposes, for example, when We use IT service providers or data storage services which are located overseas. Countries where these recipients are located may have data protection laws which differ to the data protection laws in your country of residence. 

We will disclose personal data regarding you to third parties in order to:

• enforce the Terms of Use (please hyperlink to Term of Use), and other agreements or to investigate potential breaches; or
• protect the rights, property or safety of Boehringer Ingelheim (HK) Limited, our customers, or others. This includes exchanging data with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Portions of the Site may involve linking to or using websites or services of our partner networks, third parties, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites, such as contact and location data.  Please check these policies before you submit any personal data to these websites.

7. Social Media Platforms

Communication, engagement and actions taken through external social media platforms which We attend are subject to the terms and conditions as well as the privacy policies of those social media platforms.

This Website may use social sharing buttons which help share web content directly from our web pages to the social media platform in question. Where you use such social sharing buttons you do so at your own discretion. You should note that the social media platform may track and save your request to share a web page respectively through your social media platform account. Please note these social media platforms have their own privacy policies, and We do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these social media platforms.

8. Where We store personal data 

All information you provide to us is stored on our secure servers, or those secure servers of our third-party service providers. The safety and security of personal data regarding you also depends on you.  Where We have given you (or where you have chosen) a password that enables you to access certain parts of the Sites, you are responsible for keeping this password confidential.  We ask that you do not share a password with anyone. 

Please ensure when sharing information via or from the Site (for example, on social networks or other forums), you do not submit any personal data that you do not want to be seen, collected or used by other users.

The security of personal data regarding you is a high priority. We take such steps as are reasonable to securely store personal data regarding you so that it is protected from unauthorized use or access, misuse, loss, modification or unauthorized disclosure. This includes both physical and electronic security measures. Examples include the use of passwords, locked storage cabinets and secured storage rooms. Other features include: 

• storing information on secured networks consistent with industry standards, which are only accessible by those employees who have special access rights to such systems;
• using industry-standard encryption technologies when transferring or receiving personal data;
• restrictions are placed on the electronic transfer of files; and
• our IT networks undergo necessary vulnerability testing to continually identify and remediate potential opportunities for unauthorized data access.

We takes steps to destroy or de-identify personal data when the information is no longer required for any purpose for which it may be used or disclosed by us and We are no longer required by law to retain the information.

The data that We collect from you may be transferred to, and stored at, a destination outside Hong Kong. It may also be processed by staff operating outside Hong Kong who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the provision of support services or for sending you information you have consented to via our website. By submitting personal data regarding you, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that personal data regarding you is treated securely and in accordance with this Privacy Policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect personal data regarding you, or procure that personal data regarding you is secured, We cannot guarantee the security of such data transmitted to our Site; any transmission is at your own risk. Once We have received personal data regarding you, We use strict procedures and security features to try to prevent unauthorised access.

9. Your rights 

Data protection laws give you the right to access personal data held relating to you. To protect your privacy, we may take steps to verify your identity before taking any action in response to any request. Any access request may be subject to a small fee to meet our costs in providing you with details of the personal data that we hold relating to you.  

We also want to make sure that any personal data relating to you that we hold is accurate and up to date. You may ask us to correct or remove any personal data you think is inaccurate.  

You also have the right, in certain circumstances, to:

• the erasure of personal data relating to you that We hold;
• the restriction of processing of personal data relating to you that We hold; and
• object to our processing of personal data relating to you that We hold. 

If you would like to exercise any of these rights or if you have any questions about our processing of personal data relating to you, please contact,

Boehringer Ingelheim (Hong Kong) Limited

-Data Protection Officer-

Suites 1504-9, Great Eagle Centre,

23 Harbour Road, Wanchai, Hong Kong

E-mail: webmaster@hon.boehringer-ingelheim.com

We will respect and provide you with all rights in relation to personal data relating to you that We hold, and to which you are entitled, under applicable law.

If you have a concern about the way We are collecting or using personal data relating to you, We request that you raise your concern with us in the first instance. Alternatively, you can contact the Privacy Commissioner's Office at https://www.pcpd.org.hk/.

10. Changes to our Privacy Policy

We review and amend this Privacy Policy from time to time. Any changes We may make to this Privacy Policy in the future will be posted on the Site and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Site.

11. Contact 

Questions, comments and requests regarding this Privacy Policy are welcomed and can be addressed to our Data Protection Officer by contacting us.

Boehringer Ingelheim (Hong Kong) Limited

-Data Protection Officer-

Suites 1504-9, Great Eagle Centre,

23 Harbour Road, Wanchai, Hong Kong

E-mail: webmaster@hon.boehringer-ingelheim.com

12. Pharmacovigilance

This section relates to our use and processing of personal data that you provide us in the course of reporting an adverse event or provision of pharmacovigilance relevant information regarding our product(s). Reports may be submitted to Boehringer Ingelheim (HK) Limited, Suites 1504-9, Great Eagle Centre, 23 Harbour Road, Wanchai, Hong Kong. 

Use of the personal data: We will use your personal data solely for pharmacovigilance purposes, including the investigation, detection, assessment, review, understanding and prevention of adverse effects or any other medicine-related problems associated with affected product(s), filing report with the relevant authorities as required by law, regulations best practice or our policies, and contacting you in connection with the aforesaid purpose. As reports on adverse events are important for public health reasons, the reports that you submit are normally retained for a minimum period of 10 years after withdrawal of the affected product(s) in the last country where they are marketed. 

Disclosure of the personal data: We shall disclose the report you submitted together with your personal data to Boehringer Ingelheim International GmbH, which maintains and operates the global pharmacovigilance database, in connection with the purposes mentioned above .  Boehringer Ingelheim International GmbH shall use and process your personal data subject to and in accordance with the relevant data protection laws of its jurisdiction.  
Boehringer Ingelheim may also be obliged to report pharmacovigilance relevant information to health authorities in Hong Kong and worldwide (including to countries that may have a comparable level of personal data protection with Hong Kong).¹ These reports will contain details about the incident and may also contain your personal data, including:

• For patients: age, birth date, gender and initials.  
• For reporting individuals: the name, profession (e.g. physician, pharmacist), initials, address, email and phone number. The purpose of providing contact information is to allow the health authority to make contact and follow up with the reporter for further information about the adverse event(s) concerned. 

 

Last Reviewed: May 2024