Viatris

Viatris Privacy Notice

Last Updated: September 2020

Viatris Inc. and its affiliates and subsidiaries (collectively “Viatris,” “Company,” “we,” “our,” and “us”) are fully committed to protecting the information relating to identified or identifiable natural persons (“Personal Data”) that we process.

This Viatris Privacy Notice (“Notice”) describes our collection, use, disclosure, and retention of Personal Data in relation to our websites, apps, services, and platforms, and your use of them, our marketing and provision of products and services, our interactions with you in-person, by calling us, or by mail, and otherwise during the operation of our business. The Notice also explains the ways in which you may, under applicable laws, be able to control our processing of your Personal Data and exercise other rights. This Notice does not apply to Personal Data of members of our workforce in the context of that relationship.

Depending on the way you interact with us, we may occasionally provide you additional information about our processing of your Personal Data addressing specific processing activities and circumstances. For example, where we sponsor clinical trials or offer training or other services to healthcare providers, separate privacy notices may apply to our processing of Personal Data for those and other circumstances. We refer to such notices here as “Supplemental Disclosures”. Supplemental Disclosures should be read together with this Notice. However, in the event of any conflict or inconsistency between the terms of the Supplemental Disclosure and this Notice, the Supplemental Disclosure will prevail, but only for the Personal Data processing subject to that disclosure.

The Viatris subsidiary or affiliate with which you interact is, where applicable, the data controller (or equivalent under applicable law) responsible for the processing of your Personal Data. You can find a list of the relevant legal entities that act as data controllers in Appendix 1 to this Notice. Such entities may also have separate Supplemental Disclosures.

We have appointed a Data Protection Officer (“DPO”) for jurisdictions where one is required under applicable law. However, anyone in any jurisdiction can contact our DPO with questions about our Personal Data processing activities or the contents of this Notice. Please see the “ Contact Us” Section below for information on how to contact our DPO.

Anonymous, de-identified, and aggregate data, as those terms may be defined under applicable law, are not considered “Personal Data” within the meaning of this Notice.

This Notice is comprised of the following sections:

  1. Personal Data We Collect
  2. Why We Process Personal Data
  3. Lawful Bases of Processing
  4. Disclosure of Personal Data
  5. Cross-border Transfers of Personal Data
  6. Data Security and Retention
  7. Your Choices and Rights
  8. Children's Data
  9. Revisions to this Notice
  10. Contact Us
  11. California Disclosures
  12. Appendix 1

Please note that our websites, apps, or platforms may link to content provided by third parties that we do not control and for which we are not responsible. When you navigate to such content, the relevant third parties may process your Personal Data. We encourage you to read the third parties’ privacy and cookies notices when you leave our website, app, or platform.

1. Personal Data We Collect

Viatris or third parties acting on our behalf may collect Personal Data about you from a number ofsources. We may collect Personal Data that you provide, such as when you register for an account on our website, submit an employment application to us, or sign up for a webinar or training session. We may also automatically collect Personal Data as you interact with us, such through cookies and similar technologies, including information such as collecting the IP address from which you visited our site (see further discussion of cookies at the end of this section). We also collect Personal Data from third party sources, such as obtaining information about healthcare licenses from third-party suppliers.

The types and amount of Personal Data that we collect about any particular individual would depend on the nature of our relationship with that individual and the purposes for which we use the individual’s Personal Data. We collect Personal Data from different categories of individuals, including but not limited to the following:

Personal Data That You Provide

We collect Personal Data that you choose to provide us, such as when you are registering to participate in a clinical trial, completing surveys, speaking with our customer support agents, reporting pharmacological concerns and other complaints, visiting our offices, or applying for employment, among other interactions.

Depending on your relationship with us, you might provide us the following categories of Personal Data:

Personal Data That We Collect Automatically

We may automatically collect information that constitutes Personal Data when you interact with us, such as when you visit our digital properties, read our marketing communications including emails, contact us, purchase a product from us, apply for a job, or attend events that we are hosting, among other interactions.

Depending on your interaction with us, we might collect the following categories of Personal Data:

We use cookies and related digital tracking technologies (“Cookies”) in our emails and on our digital properties. This may involve us or third parties collecting Personal Data about online activities over time and across third party websites or online services. Please read our Cookie Notice for more information about our use of Cookies. We do not currently respond to web browser Do Not Track signals or similar mechanisms.

Personal Data That We Collect from Third Parties

We may obtain Personal Data relating to you from third parties, such as when we obtain contact data from marketing list suppliers to support our marketing and sales initiatives or when we obtain professional license information to confirm information provided by healthcare providers.

The third parties from which we obtain Personal Data generally fall within the following categories:

We collect the following categories of Personal Data from third parties:

2. Why We Process Personal Data

The specific purposes for which Viatris processes an individual’s Personal Data differs based on our relationship with the individual. In general, Viatris processes Personal Data for the following purposes:

The additional purposes for which we may process what are deemed special categories of personal data under certain jurisdictions’ laws are as follows to the extent relevant, necessary and permitted by applicable local law:

3. Lawful Bases of Processing

Certain jurisdictions require that we have a lawful basis to justify our processing of your Personal Data. Where applicable, the lawful bases that Viatris relies upon to justify a particular processing activity may differ from the lawful basis used to justify a different processing activity. Viatris relies on the following lawful bases to process Personal Data, as permitted under applicable law:

We may obtain your consent to collect and use certain types of Personal Data when we are required to do so by law (for example, in relation to our direct marketing activities and our use of cookies). If we ask for your consent to process your Personal Data, you may withdraw your consent at any time by contacting us using the details at the end of this Notice. Withdrawing your consent will not affect the lawfulness of processing based on consent before its withdrawal.

Where required by law, we may obtain your explicit consent to collect and use special category data (see the end ofsection 2 above) about you. Other legal bases for our processing ofspecial category data may include, as permitted by applicable law, for scientific research, for purposes of preventative or occupational medicine or based on a contract with a health care provider or other health professional, for employment, socialsecurity or social protection law, for reasons ofsubstantial public interest, or as necessary for the establishment, exercise or defense of legal claims.

You can contact our DPO for more information about our processing of your Personal Data.

4. Disclosures of Personal Data

Where required by applicable law, Viatris does not rent, sell, or share Personal Data about you with nonaffiliated persons for their direct marketing purposes unless we have your permission. Otherwise, however, we may disclose your Personal Data to the following categories of third parties without your consent as permitted by applicable law:

We may also disclose your Personal Data to third parties such as social networking and other sites if you direct us to share your Personal Data with such sites or to other entities that do not fall in one of the above categories with your permission.

5. Cross-border Transfers of Personal Data

Viatris operates globally and consistent with applicable laws may process your Personal Data in jurisdictions that are not regarded as providing the same level of protection to Personal Data as the jurisdiction in which you are based.

When transferring Personal Data across borders, we take steps to put in place safeguards to protect such Personal Data as required by applicable laws. These safeguards may include:

Please do not hesitate to contact us if you have any question concerning the transfer of your Personal Data (see the “Contact Us”).

6. Data Security and Retention

Viatris implements various technical, administrative, physical, and organisational measures to protect the security and confidentiality of Personal Data. While we take measures to safeguard your Personal Data, we cannot guarantee that the Personal Data we process willremain secure.

Where required by law, Viatris willretain Personal Data only for as long as necessary to accomplish the purposes for which the Personal Data was collected or for the period required by the applicable laws (whichever is longer).

To determine the appropriate retention period for your Personal Data, Viatris considers the following factors:

When the retention of your Personal Data is no longer necessary for the purposes for which it was collected or our retention ofsuch Personal Data is no longer required by law, we will delete, anonymize, de-identify, or aggregate the Personal Data such that it is no longer associated with you.

7. Your Choices and Rights

Some jurisdictions have provided individuals with certain rights in relation to the processing of their Personal Data. This is the case where you or the Viatris subsidiary or affiliate with which you interact is located in the European Union or United Kingdom, though these rights may be available in other jurisdictions too. These rights are not available to everyone, and they do not necessarily apply in all contexts. Depending on applicable law, you may have the rights to:

To exercise a right that you believe you may be entitled to under applicable law, please contact our DPO. We may need to verify your identity before we fulfil your request (see also the California disclosures section below if you are a California resident).

If you feel that we have failed to comply with your request or have not addressed a complaint that you have, you may also have the right to complaint to the competent data protection or other regulatory authority in your jurisdiction.

8. Children’s Data

We do not knowingly process Personal Data relating to individuals younger than 16 without the permission of the minor’s guardian, except where permitted under applicable law. If you have reason to believe that we are processing Personal Data relating to a minor without permission from the minor’s guardian, please notify us at dataprivacy@viatris.com. Please note that in certain situation we may process minors’ Personal Data for specific activities such as clinical trials. Such processing will be subject to separate policies and procedures, including Supplemental Disclosures.

9. Revisions to this Notice

We may update this Notice from time to time. You are encouraged to consult this Notice on a regular basis and check the date on which the Notice was last updated, as shown in the beginning and end of the Notice. When we make a material change to the Notice, we will endeavour to notify you by placing a notice on our website or we will provide notice as otherwise required by law.

10. Contact Us

To exercise your rights or make a request concerning the processing of your Personal Data, you may contact us by:

11. California Disclosures

Click here for a Supplemental Disclosure for California Residents.

12. APPENDIX - List of Controllers

Click here for a table of applicable controllers and responsible entities.