Effective 25 July 2023
Pfizer respects the privacy and confidentiality of personal data. This Privacy Policy describes the personal data about you collected by Pfizer via the website/mobile application from which you linked (“Site”) and/or via other means during the course of interaction between you and Pfizer; how we use that information; how we protect it; and the choices you may make with respect to your personal data.
When we refer to ourselves as “we” or “Pfizer,” we mean Pfizer (Vietnam) Limited Company; the representative offices of Pfizer (Thailand) Limited in Ho Chi Minh City; Pfizer (Thailand) Limited and the Affiliates of Pfizer (Vietnam) Limited Company from time to time (“Affiliate” means any entity that controls, is controlled by, or is under common control with, Pfizer. For the purposes of this definition, an entity shall be deemed to control another entity if it owns or controls directly or indirectly more than fifty percent (50%) of the voting equity or assets of the other entity (or other comparable ownership interest for an entity other than a corporation) or the right to appoint a majority of the directors of the other entity (or other comparable supervisory body for an entity other than a corporation).
By continue using the Site and/or providing personal data to us and checking the box in the registration form, whichever is applicable, you hereby consent and agree to the collection, use, storage, processing, transfer, share and otherwise processing of your personal data by Pfizer and its authorized agents and contractors whether in or out of Vietnam in accordance with this Privacy Policy. Your access to and use of the Site are subject to this Privacy Policy and to our Term of Use as updated from time to time.
You may choose not to submit personal data to us, but this can result in us not being able to provide certain information, products and services to you.
Our Site may contain links to third party websites, content and services that are not owned or controlled by Pfizer. Pfizer is not responsible for how these properties operate or treat your personal data so we recommend that you read the privacy policies and terms associated with these third party properties carefully.
Our Privacy Policy is organized in the following sections. For immediate access to a particular section, click on the title.
> Information we collect and use
> How we use personal data
> How we share your personal data
> Cookies and other tools
> Online advertising
> Undesirable Consequences and Damage
> Retention Period
> Your privacy choices, updates, and other rights
> Cross border tranfers
> Personal Data Of Other Third Party
> Minors
> The Dead/Person Declared Missing
> Contact us
> Updates to our Privacy Policy
Information We Collect and Use
Depending on each specific activity, program and/or interaction between you and us, we may collect and use for our business purposes the following categories of personal information, and to the extent permitted under applicable local law:
We disclose the above categories of personal information to Pfizer Inc.’s subsidiary companies and service providers for our business purposes.
In the course of your business relationship with Pfizer, we may collect the categories of personal information described above directly from you, automatically through your use of our online products and services, and from third parties:
Information We Collect Directly From You. We collect personal data you choose to provide, e.g. when we meet with you; when you participate in our programs, activities, industry events, or trade shows; through registrations, applications and surveys, and in connection with your inquiries. For example, you may choose to provide your name, contact information, personal images, health, insurance and/or financial information in connection with a promotion, a patient assistance or support program or a clinical trial. Healthcare professionals (“HCP”) may choose to provide information relating to their specialties and professional affiliations. In addition, subject to specific activities or programs under which you interact with us, we may also collect certain sensitive personal data from you, including but not limited to health status and credit account information.
Information We Collect Automatically. To the extent permitted under applicable local law, we automatically collect information when you use our Site or online products or services that Pfizer offers, such as your browser type and operating system, web pages you access, links you click, your IP address, the length of time you visit our Site, and the referring URL, or webpage that led you to our Site. Our third party business partners may use these technologies to collect information about your online activities. See also the section below on Cookies and other tools. We may also collect your personal data via technologies and/or automated methods of personal data processing such as artificial intelligence technologies, including but not limited to image recognition, speech recognition, transcription, and natural language processing, etc., to the extent permitted under applicable local law. We will only collect and use your personal data through technologies and/or automated methods of personal data processing for the purposes described in this Privacy Policy.
Information We Collect From Other Sources. To the extent consented by you and/or to the extent required or permitted by local law, from time to time, we may use or augment the personal data we have about you with information obtained from other sources, such as public databases, social media platforms and other third parties, in accordance with this Privacy Policy. For example, we may use such third party information to confirm contact or financial information, to verify your license, to verify licensure of users or to better understand your interests by associating demographic information with the information you have provided.
If you submit any personal data relating to other people to us, you shall ensure that you have informed them of the specific content of this Privacy Policy and obtained their prior consent, if necessary, or you shall apply other legal basis to permit us to use the information provided by you in accordance with this Privacy Policy.
How We Use Personal Information
To the extent consented by you for each specific activity, program and/or interaction between you and us and/or to the extent required or permitted by local law, we may use your personal data in the following ways for our business purposes:
To Serve And Interact With You
We may use your personal data to respond to your inquiries and, subject to the local laws and regulations, provide the products and services you request. When you respond to an advertising or service offering, to the fullest extent permitted by local law, we will provide the specific materials you request as well as newsletters, articles, alerts, announcements, invitations, and other information about related activities, products, brands, health topics and disease states. We also use your information to deliver the content and services we believe you will find the most relevant. For example, a female user may receive information on diseases targeted at women that a male user may not see; a user with arthritis may receive information relating to new arthritis therapies. In addition, we may use personal identifiers to recognize you when you arrive at the Site via an external link such as a link appearing on a third party site or in an email Pfizer has presented to you. See also our Cookies and other tools section below. We will also use your information to provide customer service and support. In addition, we may also use your information to conduct internal assessment and approval procedures as necessary under our policies and/or our requirements in order to serve you. If you are a HCP, we may use your information to create and maintain an HCP database, so that we can identify and engage with you as a scientific expert or key opinion leader in various health care fields based on your professional expertise and opinions. We may also use your information to invite you to attend congresses/panels, HCP professional meetings and educational activities, or to reach out to you for your professional expertise by communicating information about our products through our professional representatives or in the context of surveys relating to pharmaceutical products or services.
For Business Administration Purposes
We use your information to manage our relationship with you, to provide and maintain our products and services, to conduct training and ensure quality control, and for other business administration purposes. For example, we may use your information to manage the terms and conditions that govern our relationship with you (e.g., medical events face-to-face or online, publications, advisory meetings, etc.); recording and transcribing meetings, generating business analysis, reports, predictions, inferences and other generative outputs such as meeting minutes, emails, presentations etc. from personal data collected under this Privacy Policy, by using technologies and/or automated methods of personal data processing, including but not limited to artificial intelligence technologies. We may also use your information to, where applicable, pay you for defined or agreed upon services or to reimburse your expenses.
To Serve Third Parties You Ask Us To Serve
Our Site may offer various tools and functionality. Some of these are provided by Pfizer while others are provided by third parties. For example, Pfizer may provide functionality on the Site that will allow you to forward and share certain content with a friend or colleague. In addition, the Site may also offer third party sharing functionality such as third party social media widgets/tools/buttons. If you choose to use Pfizer sharing functionality to refer someone to our content, activities, products or services, we will use your information and that of the individual you are sharing with to send the content or link you request.
In addition, we may offer access to third party sharing functionality, including social media widgets/tools/buttons. If you use that functionality, your use is subject to the third party’s privacy policy and terms. As with all links to non-Pfizer websites/content/services, we recommend that you read the privacy policies and terms associated with third party properties carefully.
To Validate Your Ability To Access/Use Certain Products, Services And Information
Some products, services and information we offer may only be suitable for/accessible to users meeting certain eligibility or other criteria. In such cases, we may verify that you meet such criteria. For example, certain information relating to our products is only intended for and accessible to licensed HCPs and we may use information we collect directly from you and from outside sources to validate your licensure and eligibility to view such information. We may also use your information for authentication purposes when you enter your login ID and/or password to enter one of our registration or login portals.
In Accordance With Special Program Terms
On occasion, Pfizer may offer special programs, activities, clinical trials, events or advertising activities via the Site or links contained therein (“Special Programs”) that have specific terms, privacy notices and/or informed consent forms that explain how any personal data you provide will be processed in connection with the Special Program (“Special Program Terms”). Pfizer will honor those Special Program Terms with respect to your personal data. Some of these Special Programs may involve sharing information with a third party and Pfizer will provide you with notice of this and obtain your consent. You may be offered the opportunity to agree to or opt out of the sharing of your information with such third party. But, in some instances, it may be necessary to agree to sharing with a third party in order to participate in a particular Special Program. If you consent/do not opt out, we will share your information with the third party; and the personal data you provide may be used by the third party in accordance with the Special Program Terms and, unless provided otherwise in such Special Program Terms, for their own purposes in accordance with their own policies/terms. We strongly suggest you review both the Special Program Terms and any applicable third party policies/terms before participating.
To Improve Products And Services And Protect Patients And Consumers
We use the information you provide to better understand how our products and services impact you and those you care for, to track and respond to concerns, for fraud prevention, public safety and labor safety, conducting incident investigations and to further develop and improve our products and services. For example, you may be invited to participate in a survey relating to our products or services or relating to your interaction and experience with our products, services, programs and activities or participation in various programs or panels of experts, or, if you are an HCP, for purposes of analyzing and predicting HCP preferences in order to identify aggregated trends to develop, improve or modify our products, services, and business operations. In addition, we use the information you provide to comply with our regulatory monitoring and reporting obligations including those related to anti-bribery, anti-corruption and compliance, adverse events, product complaints, patient safety, and/or other vital interests (e.g., prevention or suppression of danger to life, body or health) of any person.
To Identify Those Who Benefit From/Recommend Our Products/Services
From time to time, to the extent permitted by local law, we seek out individuals who have benefitted from or recommend our products and services.
For Improvement And Internal Reference
We may use your personal data for our improvement of Site and internal reference.
It is important to note that no information presented in the Site is intended as a substitute for the clinical judgments of the HCPs. You should examine and independently verify the contents and the information provided through the Site and are solely responsible for their use or misuse under any circumstances.
Marketing And Promotional Purposes
We may use your information to tailor the content and information that we send or display to you to your professional area and interests, and to otherwise personalize your experience when you interact with us. We may also use your information to send you news and newsletters, event updates, and to communicate with you about scientific and health matters.
To Comply With Law/Protect
We reserve the right to collect and use your personal data as required by law, when the collection and/or use is necessary to comply with a regulatory requirement, judicial proceeding, court order, or legal process served on us, or to protect the safety, rights, or property of our customers, third parties, the public or Pfizer. For example, we use your information to comply with our regulatory monitoring and reporting obligations, including those related to adverse events, product complaints, and product safety, as well as to comply with our anti-corruption and transparency obligations.
For The Purposes Of Legitimate Interests
To the extent consented by you or in accordance with local law, we may collect and use your personal data for our legitimate interest, including without limitation, for transferring your personal data within Pfizer Group companies and entities, preventing fraud, data breaches or cyber attacks, improving customer experiences; investigating, preventing, or taking action regarding suspected or actual illegal activities, misconduct, fraud, situations involving potential threats to the safety of any person or to otherwise protect and enforce our rights, privacy, safety or property, and/or those of our affiliates, you, and others; and/or litigation purpose.
For The Purposes Of Public Interests
We may collect and use your personal data for public interest, including without limitation, for the benefit of studying or compiling statistics for the public interest of which your personal data will be kept confidential and for performance of our other task(s) for public interest.
For Performance Of Our Contract With You
We may collect and use your personal data if it is necessary for the performance of a contract with us that you are a party, or to proceed with your request before entering into such contract with us.
In Aggregated Or De-Identified Form
We may aggregate and/or de-identify information about visitors to our Site and use it for any purpose, including product and service development and improvement activities. To the extent we deidentify any information originally based on personal data, we will maintain and use such information only in deidentified form and will not reidentify the information.
How We Share Your Personal Information
To the extent consented by you by accessing our Site and/or by interacting with us through other means and/or to the extent required or permitted by local law, Pfizer may share your personal data for our business purposes as follows:
Within Our Family Of Companies
Pfizer Inc., Pfizer (Vietnam) Limited Company and its Affiliates may disclose your personal data amongst and between each other for the purposes set forth in this Privacy Policy.
In Connection With Business Transfers
If we sell or transfer a business unit (such as a subsidiary) or an asset (such as a website or an application) to another company (including in connection with any bankruptcy or similar proceedings), we may share your personal data with such company and require such company to use and protect your personal data consistent with this Privacy Policy. We may also disclose your personal data to companies that were formerly wholly or partly included in the Pfizer Inc. and Pfizer family of companies to whom we provide services during a transition period following separation, merger.
With Service Providers And Business Partners
We may retain other companies and individuals to perform services on our behalf and we may collaborate with other companies and individuals with respect to particular products or services (collectively, “Providers”). These third parties may be provided with access to personal data needed to perform their functions, but they may not use such information other than on our behalf or subject to contracts that protect the confidentiality of the information. Examples of Providers include data analysis firms, credit card processing companies, customer service and support providers, email and SMS vendors, data analytics firms, web hosting and development companies and fulfillment companies, providers of data technology and related infrastructure that allows us to organize and stream online conferences. Providers also include our co-promote partners for products that we jointly develop and/or market with other companies. Some Providers may collect information on our behalf on our Site. These third parties may be provided with access to personal data needed to perform their functions, but they may not use such information other than on our behalf and subject to contracts that protect the confidentiality of the information. In addition, as noted above, we may share information with third parties in accordance with Special Program Terms unless you opt out/do not consent.
With Business Partners
We may disclose your information to our business partners, including companies and organizations with which we collaborate regarding joint development, distribution, and/or marketing of particular products and services.
To Comply With Law/Protect
We reserve the right to disclose your personal data as required by law, when we believe disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request or legal process served on us, or to protect the safety, rights, or property of our customers, the public, Pfizer or others.
For The Purposes Of Legitimate Interests
We may share your personal data for our legitimate interest, including without limitation, for transferring your personal data within Pfizer Group companies and entities, preventing fraud, data breaches or cyber attacks, improving customer experiences, and/or litigation purpose.
For The Purposes Of Public Interests
We may share your personal data for performance of our task(s) for public interest.
For The Purposes Of Vital Interests
We may share your personal data for vital interests, including without limitation, to prevent or suppress of acts causing potential danger to life, body or health of any person.
For Performance Of Our Contract With You
We may share your personal data if it is necessary for the performance of a contract with us that you are a party, or to proceed with your request before entering into such contract with us.
In The Aggregate/De-Identified Form
Pfizer may share also disclose aggregate or de-identified information that is not personally identifiable to third parties for any purpose permitted under applicable law.
Cookies and Other Tools
Pfizer and its business partners collect information about you by using cookies, tracking pixels and other technologies (collectively, “Tools”). We use this information to better understand, customize and improve user experience with our websites, services and offerings as well as to manage our advertising. For example, we use web analytics services that leverage these Tools to help us to understand how users engage with and navigate our Site, e.g. how and when pages in a site are visited and by how many users. We may offer our users a more customized, relevant experience on our Site using these Tools by delivering content and functionality based on your preferences and interests. If you have provided us with personal data, e.g. through a registration or a request for certain materials, we may associate this personal data with information gathered through the Tools. This allows us to offer increased personalization and functionality on the Site.
Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies visit www.aboutcookies.org.
Online Advertising
During the course of your access to our Site, you may experience certain online advertising contents. If you have any questions about this, please do not hesitate to contact us at +84 28 3622 4000.
Undesirable Consequences and Damage
We use technical, administrative and procedural measures in an attempt to ensure confidentiality, safety, compliance with the law, minimization of unexpected consequences and damage (including but not limited to: unauthorized access to personal data, personal data leakage or improper processing of personal data that may cause harm to your legitimate rights and interests). However, in fact there may be risks that those measures cannot guarantee 100% that your personal data and other information will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy or appropriateness of the measures we use to safeguard such information.
If you elect not to provide consent to Pfizer for any or all of the processing purposes, the possible undesirable consequences may include your inability to interact with Pfizer and/or termination of the relationship between you and Pfizer, with regard to the relevant processing purpose(s) without your consent.
Retention Period
We will retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and as outlined in this Privacy Policy. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to the enforcement of the contractual terms and conditions that govern our relationship with you, applicable statutes of limitations, litigation or regulatory investigations).
Your Privacy Choices, Updates and Other Rights
You may always request to access and/or update your personal data and your preferences. Limited communications may be necessary in order for you to participate in a particular program or service. Different programs and services may offer different phone numbers, links or preference managers that allow you to inform us of your updates and choices, including opting out of particular communications. These contact options are typically available on our Site or in the emails or texts we send but you may always contact our officer for assistance at the contact information provided below if you have any difficulty finding these tools or otherwise updating your information or preferences.
We will keep (and you may request us to keep) your personal data accurate, up-to-date, complete, and not misleading.
You have the following rights:
You have the right to be free from unlawful discrimination for exercising your rights under applicable law.
You may request that we delete or destroy or temporarily suspend the use of your personal data held by us, or convert it into the information which cannot be used to identify you (this right only occurs if we fail to comply with our obligations under Vietnam applicable data protection laws, if any).
Cross Border Transfer
The Site is controlled and operated by us from Vietnam and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of Vietnam. Any information you provide to Pfizer through use of the Site or through the registration form may be stored and processed, transferred between and accessed from Vietnam and other countries, for the purpose the information was collected, which may not guarantee the same level of protection of personal data as the one in which you reside. However, Pfizer will comply with applicable laws and regulations and will use our best endeavors to ensure that your transferred information will be processed in accordance with this Privacy Policy. By giving consent to this Privacy Policy and/or providing personal data to us and checking the box in the registration form, whichever is applicable, you consent to Pfizer's cross-border transfer of your personal data in accordance with this Privacy Policy.
Personal Data of Other Third Party
If you provide personal data of another person to Pfizer, you represent and warrant to Pfizer that you have informed such person of the personal data processing activities under this Privacy Policy or showed such person a copy of this Privacy Policy and obtained legitimate consent of such person in accordance with applicable laws prior to sharing his/her/their personal data with us, or apply other lawful bases to ensure that Pfizer can collect, store, use, process and/or disclose/share personal information of the aforementioned third party. You will indemnify Pfizer for any cost, charge, damage, expenses or loss incurred to Pfizer due to your failure to comply with this provision.
Minors
If you provide personal data of a minor to Pfizer, you represent and warrant to Pfizer that:
If Pfizer learns that the collection and/or processing of personal data of minors is undertaken without necessary consent given by the parent(s)/legal guardian and, for case of a minor who is from seven (7) to under sixteen (16) years of age, by the minor himself/herself, Pfizer shall delete irrevocably or destroy such personal data immediately, or the collection and/or processing of the personal data shall be undertaken only for the cases where Pfizer can apply other lawful bases that require no consent. Pfizer will take necessary steps to verify the age of minors prior to processing his/her personal data.
The Dead/Person Declared Missing
If you provide personal data of a dead person or a person declared missing to Pfizer, you represent and warrant to Pfizer that consent by the spouse or adult child of the dead or the person declared missing is given. If there is no such person, consent by the parent of the dead or the person declared missing must be given.
If Pfizer learns that the collection and/or processing of personal data of the dead or the person declared missing is undertaken without necessary consent given, Pfizer shall delete irrevocably or destroy such personal data immediately, or the collection and/or processing of the personal data shall be undertaken only for the cases where Pfizer can apply other lawful bases that require no consent.
Contact Us
You may submit requests to delete, correct, access a copy and/or know personal information we have collected about you by contacting us according to the information below. You will be asked to provide certain personal information when submitting your request including your relationship with Pfizer, first and last name, email address, telephone number and postal address in order for us to determine if your information is in our systems.
We will further verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. We may need to request additional personal information from you, such as your date of birth or government identifier, in order to protect against fraudulent or spoofed requests. If you want to make a request as an authorized agent on behalf of an individual under applicable local law, you may use the submission methods noted above. As part of our verification process, we may request that you provide us with proof that you have been authorized by the individual on whose behalf you are making the request under applicable local law, which may include signed permission provided by such individual.
PFIZER (VIETNAM) LIMITED COMPANY OR
THE REPRESENTATIVE OFFICE OF PFIZER (THAILAND)
LIMITED IN HO CHI MINH CITY
Floor 17, Unit 1701, Friendship Tower, 31 Le Duan
Ben Nghe Ward, District 1,
Ho Chi Minh City, Vietnam
Tel: +84 28 3622 4000
Updates to Our Privacy Policy
From time to time, we may update this Privacy Policy. Any changes will be effective immediately upon the posting of the revised Privacy Policy. If the Privacy Policy changes in a way that significantly affects how we collect, use, store, process, disclose, share and/or transfer your personal data, we will not use, store, process, disclose, share and/or transfer the personal data we previously gathered in the manner described in the new policy without providing notice and/or obtaining your consent. After such material change, you may choose not to provide your consent to us, but this can result in us not being able to provide certain information, products and services to you. Minor changes to the policy without notice or consent may occur but will not affect how we collect, use, store, process, disclose, share and/or transfer your personal data. We will obtain your consent to changes to this Privacy Policy if required by the applicable law.
We encourage you to periodically review this page for the latest information on our privacy practices. This Privacy Policy was updated as of the effective date listed above.