Effective Date: December 4, 2018

I. Introduction

We value your privacy. Our purpose is to share information about Access Accelerated, its members and programs. We collect your personal data when you visit the Access Accelerated Open Platform (“Platform”) and Website (“Website”), register for our newsletters and when you otherwise decide to provide us with your data, for instance by contacting us. This Website Privacy/Cookie Notice (“Notice”) describes how the International Federation of Pharmaceutical Manufacturers & Associations located at Chemin des Mines 9, P.O. Box 195, 1211 Geneva 20, Switzerland (“IFPMA”, “we”, “our” and “us”) processes personal data collected or received from visitors (“Visitors”) of the Platform. It also describes how we use personal data collected when you register to receive our newsletters. For purposes of Swiss data protection law, IFPMA acts as data controller responsible for your personal data. This Notice applies to all websites within the accessaccelerated.org domain name and the aaopenplatform.org.

II. What Information Do We Collect when You Visit our Platform or Website

We collect personal data from you through your use of our Website and Platform in various ways. You may choose to submit your personal data and other information to us through various communication channels provided on our Website or Platform, for example, Access Accelerated e-mail addresses, telephone numbers or online forms. When you choose to subscribe to our newsletters you will be prompted to provide us with information that helps us identify you, such as your name, email address, and organization.

Where we ask you to provide us with your personal data, we will indicate whether providing the personal data is a statutory or contractual requirement, or a requirement necessary to enter into and/or facilitating a contract, as well as whether you are obliged to provide the personal data and of the possible consequences of a failure to provide the personal data. Subscribing to our newsletters or Website is optional. If you choose not to subscribe or provide personal data, you can still use the Website. However, you will not receive our newsletters.

We also use cookies or similar technologies that collect certain Website and Platform usage information when you access, view and use the Website or Platform. A cookie is a data file placed on a computer or mobile device when it is used to visit websites. Below is an overview of the cookies we use and why we use them:

• The following cookies are not essential for our Website and Platform to function, but are generally used to provide, maintain and improve our services or your user experience.

You may disable cookies in your browser’s settings (e.g., under the “Preferences” or “Internet Options” features of your browser). Note, however, that some features of the Website may not function properly if you disable the use of cookies, and that you may need to re-enter your information or log-in details. For detailed information on how to manage or delete cookies, visit http://www.allaboutcookies.org/. If you would like to opt-out from Google Analytics cookies specifically, you can also download the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.

III. The Types of Personal Data We Collect From Website Visitors

Through the cookies listed above under the section “What Information Do We Collect when You Visit our Platform or Website” we collect information regarding your Website usage, IP-address, browser type and operating system. We also collect and process the preferences you select, such as your language preference.

In addition, through the communications channels made available on the Website’s “Contact Us” webpage, including the newsletter registration page, we collect the personal data you choose to provide us with, namely your contact details, such as your name, email address, address, telephone number, fax number and organization name. You may also voluntarily provide other personal data in connection with your inquiries or comments. We encourage you, however, to provide no more personal data relating to you than is necessary in order for us to provide an appropriate response to your inquiries or comments.

IV. How We Process the Personal Data We Collect

We only process your personal data to the extent it is necessary (i) for the performance of your agreement with us or in order to take steps at your request prior to entering into an agreement with us; (ii) to comply with our legal obligations; or (iii) to pursue our legitimate interests, such as providing, evaluating and improving our services. Note that we have carefully balanced our legitimate business interests against your data protection rights. Please contact us using the contact details listed below if you would like to receive more information on this.

• Manage your newsletter registration
• Address your comments or inquiries when you reach out to us.
• Communicate with you.
• Operate, evaluate and improve our services and facilitate your use of our websites.
• Perform accounting, auditing, billing and collection activities.
• Comply with applicable legal requirements, industry standards and our policies.
• Operate, evaluate and improve our services and
• Prevent and protect us and others against fraud, unauthorized transactions, claims and other liabilities.

V. How We Share Personal Data

We do not sell, rent or trade your personal data. We share your personal data with:

• Our main partnering association, the International Federation of Pharmaceutical Manufacturers & Associations (“IFPMA”), in case it is reasonably necessary or desirable for us to disclose your personal data
• Providers of Infrastructure- or Platform- or Software-as-a-Service solutions, software development services, information system maintenance services, record management services or marketing services, and other third party service providers and
• Government authorities or other third parties, if required by law, upon official request or to the extent reasonably necessary to protect the rights, legal interests, property or safety of others or ourselves.

VI. International Data Transfers outside Switzerland

We transfer the personal data we collect about you to our Partners and Members, which may be located in countries other than the country in which the data was originally collected. When we transfer your personal data to countries outside Switzerland, we will protect that data as described in this Notice and in accordance with applicable law. This means we will put in place appropriate data transfer mechanisms where legally required.

VII. How We Protect Personal Data

We maintain appropriate technical and organizational security safeguards designed to protect the personal data we process against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

VIII. How Long We Retain Personal Data

We store personal data only as long as necessary to fulfil the purposes for which we collect the data (see above under “How We Process the Personal Data We Collect”), except if required otherwise by law. Please contact us using our contact details provided below, if you have any questions with respect to our data retention practices.

IX. Links to Other Websites

The Website may contain links to websites maintained by third parties, whose information and privacy practices are different than ours. We are not responsible or liable for the information or privacy practices employed by such third parties. We encourage you to read the privacy statements of all third party websites before using such websites or submitting any personal data or any other information on or through such websites.

X. Children's privacy

We do not knowingly collect any personal data from children under the age of 13 and does not direct its Website or Platform to children. If you think that your child provided personal data to us, we strongly encourage you to contact us immediately and we will work with you to find a solution to remediate this.

XI. Updates to the Website Privacy Notice

We reserve the right to modify this Notice at any time. If we make changes to this Notice, we will notify you through regular communication channels if we have your contact details (e.g., e-mail) or through a prominent posting at the top of the Notice indicating the change in effective date.

XII. Your Data Protection Rights

Your rights under applicable law may include access to the personal data we process about you, the right to have such personal data corrected, erased or cancelled, the right to restrict the processing of your personal data, and the right to withdraw your consent, if we have asked you to consent to processing of your data. You also have the right to lodge a complaint with the Swiss Supervisory Authority.

In addition, you have the right to object to the processing of your personal data if that processing is based on our legitimate interests.

To exercise these rights, please send a written request to our Data Protection Officer using the contact details set out below. All requests to exercise your data protection rights should include at least the following:

• Your full name and the email address, at which you would like to receive our response to your request
• A copy of your ID card with your photo
• A clear and precise description of the rights you want to exercise and your specific request
• For requests related to your right to correct personal data, the modifications to be carried out.

XIII. How to Contact Us

If you have any comments or inquiries about this Notice, if you would like to update your personal data, or to otherwise exercise your data protection rights, you may contact us at info@accessaccelerated.org or by letter at Access Accelerated, Chemin des Mines 9 P.O. Box 195, 1211 Geneva 20, Switzerland.