Version Date: 25 November 2019
Scope of this Privacy Notice
Biogen MA, Inc. of 225 Binney Street, Cambridge, MA 02142, USA (“Biogen”) has created this neurology website Neurodiem to provide information, education and tools to neurosciences healthcare professionals to stay up to date in their medical and scientific knowledge. This Privacy Notice describes what “personal information” (meaning any information relating to an identified or identifiable natural person) we need to collect from you on the website, how we use it and why, as well as your rights in relation to this collection and use. You are under no obligation to provide personal information to us, but should you decide not to, you will be unable to gain complete access to the website and its content.
Information we collect and how we use it
The website collects different types of personal information depending on how you use it. By registering for the website and providing us with your personal information, you give us your consent to the processing of your personal information for the purposes set out below.
If you choose to register to use the website, you will need to create an account and user profile on the website. We may collect the following necessary personal information from you to do this: your name; title; e-mail address; password; postcode; and practitioner/physician licence or identification number. It is necessary for Biogen to have this information to: (a) verify that you are a neurosciences healthcare professional; (b) create and manage your account; (c) tailor your user experience and provide you with information that matches your specialty and areas of interests; and (d) provide you with local technical and administrative support, where necessary.
The website gives you access to various tools and content on neurology (including articles, publications and videos). Your personal information mentioned in the “Website registration” paragraph above will be used to tailor some of this content specifically to your specialty and previous preferences.
If you provide your additional consent by checking the relevant check box on the website during registration or within the account preferences page, Biogen and Biogen’s other group companies (including Biogen Canada Inc.) will use your personal information to send you direct marketing communications (including newsletters, therapy information, insights about diseases, clinical trial information, patient education materials, and invitations to attend meetings or congresses or participate in market research surveys). You may unsubscribe from, and withdraw your consent to, receiving such communications at any time and you may also manage your preferences on the website by logging in to your account. This does not, however, affect the lawfulness of the processing before your withdrawal of consent.
We may use your personal information and other information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable law.
Data collection technologies, interest-based advertising and “Do Not Track”
The website collects aggregated personal information from you to assess how it is being used.
(a) Google Analytics - It does this by using specific tagging technology called Google Analytics which provides Biogen with information on how the website is being used, including preferences, which pages have been visited, which resources have been read, shared or downloaded, which videos have been watched or shared and the progress of any resources being read or watched. Biogen analyses this information automatically, using an algorithm designed to improve the website and to deliver content tailored to its user’s specialty and areas of interests. The website also uses Google Analytics to collect aggregated personal information from you to assess: (a) the number of times the website is visited; (b) the number of accounts that are created; and (c) the amount of times an article is read or a video is viewed. This data collection technology allows us to distinguish you from other users of this website and to enhance this website and your experience when you use it.
(b) Hotjar – We also use Hotjar to analyse users’ behaviour in their usage of the website to improve the user experience.
We also use other data collection technologies provided by our ad management partners and other third parties to manage our online advertising program. We, and our ad management partners, may use the technologies to track the actions of users of the website, to measure statistics of our marketing efforts, and to deliver advertisements on third party websites. We support the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance. This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these principles can be found at www.aboutads.info. If you want to “opt out” of receiving online interest-based advertisements, please follow the instructions at www.aboutads.info/choices or www.networkadvertising.org/choices. An “opt-out” cookie will be placed on your device indicating that you do not want to receive interest-based advertisements. If you delete cookies on your device generally, you will need to opt-out again. Please note that when you “opt-out” of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us. It means that the online ads that you do see will not be based on your interests. When you “opt-out” of receiving interest-based advertisements through one of the links above, these data collection technologies may still collect information about your use of the websites, including for analytics.
How we share your information and international transfers
Biogen engages service providers to assist it in the administration of its data processing activities in relation to the website. These include the companies which: (a) provide Biogen with validation that you are a neurosciences healthcare professional; (b) help us to improve the content and design of our website; (c) provide you with direct marketing communications on our behalf, if you have provided your consent to receiving them; (d) provide Biogen with technical and administrative support; (e) provide Biogen with data collection technologies and interest-based online advertising; and (f) host the website and your personal information in the cloud and provide Biogen with data storage facilities.
Other Biogen companies
Biogen may also share your personal information with other companies in the Biogen group for the purposes described in this Privacy Notice including Biogen Canada Inc. of 90 Burnhamthorpe Rd W #1100, Mississauga, ON L5B 3C3, Canada and Biogen International GmbH of Neuhofstrasse 30, 6340 Baar, Switzerland. In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.
Ensuring protection of your data
The transfers mentioned above may include transfers outside of Canada to countries which do not implement an adequate level of protection for your personal information under Federal or provincial law. While such information is outside of your country, it is subject to the laws of the country in which it is located, 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. Biogen always takes appropriate steps to ensure your data is adequately protected if transferred to such countries.
How we store your personal information and your rights
We retain your personal information as long as your account remains active and you may deactivate your account at any time. We will also retain your information for as long as is necessary for us to comply with our legal obligations and best practice for a responsible pharmaceutical company.
You may contact Biogen at any time if you would like to access and receive your personal information or require information about the personal information that we hold about you. We may require that you provide sufficient identification to fulfil your request to access or correct your personal information. Any such identifying information will be used only for this purpose.
If, at any time, you have questions or concerns about this Privacy Notice or the processing of your personal information, you can contact Biogen by using the “Contact us” feature on the website. You may also contact Biogen’s Data Privacy Officer at firstname.lastname@example.org.