Data Privacy Statement
1. Handling of personal data
At Grünenthal, we believe transparency is the foundation of trustful collaboration. Below we’ll provide you with information on how we handle your personal data when you use our website. We handle your personal data because this is necessary to make certain functionalities of our website available and give you the best possible experience. Unless otherwise indicated, the legal basis for the handling of your personal data results from the fact that such handling is required to make available the functionalities of the Website requested by you (Art. 6(1)(b) General Data Protection Regulation).
1.1 Using our Website
1.1.1 Accessing our Website
When you call up our Website, your browser will transfer certain data to our web server. This is done for technical reasons so that we can make the information you request available. In particular, the following data are collected, briefly stored and used:
- IP address
- Date and time of access
- Time zone difference to Greenwich Mean Time (GMT)
- Content of request (specific site)
- Status of access/HTTP status code
- Transferred volume of data
- Website requesting access
- Browser, language settings, version of browser software operating system and surface
We will also store such data for a limited period of time so that we are able to initiate a tracking of personal data in the event of actual or attempted unauthorized access to our servers (Art. 6(1)(f) General Data Protection Regulation).
1.1.2 Setting of cookies
What are cookies?
Our website uses so-called “cookies”. Cookies are small text files that are stored in the memory of your terminal via your browser. They store certain information (for example your preferred language or site settings). Your browser may retransmit these to us when you revisit our website, depending on the lifespan of the cookie.
What cookies do we use?
We differentiate between two categories of cookies: (1) functional cookies which are necessary for the functionality of our website and (2) optional cookies. These are used for website analysis and marketing purposes. The following tables contain a detailed description of the optional cookies we use:
|Tool||Purpose and content||Lifespan|
|Website analysis with Sitecore Experience Analytics:||These cookies assign a randomly generated ID to your device. This enables us to recognize your device next time you visit. For details on website analysis please see the respective chapter below. dentification of a visit to be able to optimise the analysis of web site use. No personal data will be recorded.||Duration of session: This cookie is deleted if the browser is closed|
|Tool||Purpose and content||Lifespan|
|Website analysis with Google Analytics:||Website analysis with Google Analytics:
These cookies assign a randomly generated ID to your device. This enables us to recognize your device next time you visit. For details on website analysis please see the respective chapter below.
|Identification of visit tracking disabled|
Subject to your consent
We only use optional cookies if we have obtained your prior consent (Art. 6(1)(a) General Data Protection Regulation). When you visit our website for the first time, a banner will appear asking you to give us your consent to the setting of optional cookies. If you consent, we will place a cookie on your computer and the banner will not appear again as long as the cookie is active. After expiration of the cookie’s lifespan, or if you actively delete the cookie, the banner will reappear the next time you visit our website and will again ask you for your consent.
How to prevent the setting of cookies
This may, however, lead to a restriction of the functions or have adverse effects on the user-friendliness of our Website. You may object to the setting of optional cookies at any time by using the respective objection option indicated in the table above.
1.1.3 Website Analysis
This Website uses the web analytics service “Sitecore Experience Analytics” in order to help us continually improve the customer friendliness of our Website. Sitecore uses "cookies" that are stored on your computer and allow your use of the Website to be analyzed. The information generated by the cookie on your use of this Website is transmitted to and stored by state of the art secured EU based cloud servers (Azure Cloud, Dublin). You can use a corresponding setting in your browser software to prevent cookies from being saved; we would, however, like to draw your attention to the fact that, if you do so, you may not be able to use all of the functions offered by the website in full.
Google Tag Manager
This Website uses GTM (Google Tag Manager) to initiate and control the connection to Google Analytics. It is used most of all to minimize administrative effort and to analyze reporting problems.
On our Website we use Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (hereinafter “Google”). Google will analyze your use of our website on our behalf. To this purpose we use, among others, the cookies described in more detail in the above table. The information collected by Google in connection with your use of our website (for example the referring URL, our webpages visited by you, your browser type, your language settings, your operating system, your screen resolution) will be transmitted to a server of Google in the USA, where it will be stored and analyzed. The respective results will then be made available to us in anonymized form. Your usage data will not be connected to your full IP address during this process. We have activated on our Website the IP anonymizing function offered by Google, which will delete the last 8 digits (type IPv4) or the last 80 bits (type IPv6) of your IP address. Moreover, Google is certified under the EU-US Privacy Shield, which ensures that an adequate level of data protection is maintained with respect to the processing of data by Google in the US.
By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
The Google Analytics tracking code implemented on this website supports display advertising. The remarketing function is used for Google Analytics display advertising on this website.
The ads are displayed on the websites by third-party providers including Google. The combined use of first-party cookies (e.g. Google Analytics) and third-party cookies (e.g. DoubleClick cookies) enables us to personalise, adapt and optimise the ads we display on this website based on your previous visits. You can use the Ads Preferences Manager to deactivate Google Analytics for display advertising and adapt ads in the Google Display Network.
The following Google AdWords functions are used on this website:
- Interest categories
- Similar target groups
- Other types of interest-based advertising
We use these Google AdWords functions in order to make visitors to this website aware of websites of third-party providers or to address internet users with specific interest profiles, based on their internet usage. We do not gather personal information with our cookies, remarketing lists or other anonymous IDs.
General information on online behavioural advertising
Online behavioural advertising, also known as targeting, enables advertising companies to identify users and assign them to particular target groups when delivering advertisements. This information makes it possible to display ads that are more relevant to the user.
Behavioural advertising takes place in three stages: data collection via "tracking pixels", storage and processing of log file information and finally using this information when the user returns for retargeting or lookalike retargeting. We would like to explain these steps in a little more detail below.
Use of tracking pixels on the website
Tracking pixels are small images on websites that are used for log file recording and log file analysis for statistical evaluation. When visiting a website, the tracking pixels write information to the cookie file in the user’s browser.
1.1.4 Use of contact forms
You can contact us directly by using the contact forms available on our website. In particular, you may provide us with the following information:
- name, surname and title
- Address (Street, Postal Code, City)
- contact data (e.g. e-mail address, phone number)
We collect, process and use the information you provide via the contact forms exclusively for the processing of your specific request.
Additional notice for your posting of patient stories
We will collect your Related Personal Data (e.g. patient story including health data, pictures) for the Specified Purpose of sharing your first name, age and personal story on menotmigraines.com and the associated menotmigraines Instagram & Facebook account.
We will only use your personal data when the law allows us to. We will use your story and personal data in the following circumstances:
- on the basis of your consent to share on our website and social accounts;
- where we need to comply with a legal or regulatory obligation.
1.1.5 Subscription to our newsletter
You may subscribe to receive our newsletter from our website. Based on your prior consent, we will collect and use the email address you indicate for providing you with the newsletter (Art. 6(1)(a) General Data Protection Regulation).If you wish to receive a customized newsletter, you may, on a voluntary basis, provide us with the following additional information:
- Name and surname
- Media, Department
- City, Country
- Subject(s) of interest
For subscription to our newsletter we use the so-called double opt-in procedure. After you subscribe to the newsletter, we will send you a message to the indicated email address asking for your confirmation. If you do not confirm your subscription, your subscription will automatically be deleted. In order to prevent any misuse of your personal data, we will log your subscription and confirmation, filing the IP address you use when subscribing, the time of your subscription and confirmation, the messages sent by us regarding your subscription, and the wording of your subscription and confirmation.
You may revoke your consent to receive our newsletter at any time with future effect. To declare that you wish to unsubscribe, you may use the respective link included in all newsletters, or refer to the contacts indicated below.
1.1.6 External services or content on our Website
We include third-party services and/or content on our website. When you use such third-party services or when third-party content is displayed, communication data are exchanged between you and the respective provider for technical reasons. The respective provider of the services or content may also process your data for own additional purposes. To the best of our knowledge, we have configured the services and content of providers known to process data for own purposes in such a way that either any communication for other purposes than to present their services or content on our website is blocked, or communication only takes place once you have actively opted to use the respective service. However, since we have no control over data collected and processed by third parties, we are not in a position to provide binding information regarding the scope and purpose of such processing of your data.
For further information regarding the scope and purpose of such collection and processing of your data, please consult the privacy statements of the providers whose services and/or content we include and who are responsible for the protection of your data in this context: For the purpose of an interactive design of our website third-party content from YouTube and Vimeo is integrated into this website. This serves to safeguard our predominant legitimate interests in a multimedia presentation of our services and our activities in accordance with Art. 6 (1) Clause 1 lit. f GDPR.
This website uses plug-ins from the American company Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA ("Google") which Youtube is operated by. As a consequence, log information may be transmitted from our website to Google. Google’s server in the United States thus automatically stores information (“log data”), such as the information that your browser sends to a website when you visit, or the information that your mobile app sends when you use it. This log data may contain your IP address, the address of the website you visited that uses Google features, the browser type and settings, the date and time of your request, information about your use of Google, and cookies.
Youtube / Google: https://www.google.com/intl/en/policies/privacy/
This website uses plug-ins from the American company Vimeo, LLC, 555 West 18th Street, New York, New York 10011, USA. As a consequence, log information may be transmitted from our website to Vimeo. Vimeo’s server in the United States thus automatically stores information (“log data”), such as the information that your browser sends to a website when you visit, or the information that your mobile app sends when you use it. This log data may contain your IP address, the address of the website you visited that uses Vimeo features, the browser type and settings, the date and time of your request, information about your use of Vimeo, and cookies.
Use of Facebook, Google+, LinkedIn Twitter and Instagram Plugins
We use so-called social plugins ("plugins") from the social networks Facebook and Google+ and the microblogging services Twitter and Instagram on our website. These services are provided by the following companies: Facebook Inc., Google Inc., Twitter Inc. and Instagram LLC ("providers").
Data protection for the use of Facebook plugins (like button)
On our pages, plugins from the social network Facebook, provider Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA, are integrated. You can recognize the Facebook plugins on the Facebook logo or the “Like-Button” on our page. An overview of the Facebook plugins can be found here: developers.facebook.com/docs/plugins/
When you visit our pages, the plugin creates a direct connection between your browser and the Facebook server. Facebook will be informed that you have visited our site with your IP address. If you click the Facebook “Like button” while you are logged in to your Facebook account, you can link the content of our pages to your Facebook profile. This allows Facebook to associate the visit of our pages with your user account. We would like to point out that as a provider of the pages we do not receive any knowledge of the content of the transmitted data as well as their use by Facebook. For more information, see Facebook’s Privacy Statement at http://en-de.facebook.com/policy.php.
If you do not want Facebook to associate the visit of our pages with your Facebook user account, please log out of your Facebook user account.
Conversions measurement with Facebook Pixel
With your consent, we use the "visitor action pixel" of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA ( "Facebook") within our Internet presence. We can use it to track the actions of users who have seen or clicked on a Facebook ad. This allows us to track the effectiveness of Facebook advertising for statistical and market research purposes. The data collected in this way is anonymous for us, ie we do not see the personal data of individual users. However, this data will be stored and processed by Facebook, which will be communicated to you according to our knowledge. Facebook can connect this data with its Facebook account and also use its own advertising, according to Facebook's data usage policy https://www.facebook.com/about/privacy/ . You can enable Facebook as well as its partners to turn advertising ads on and off Facebook. For this purpose, a cookie can also be stored on your computer.
This consent may be declared only by users older than 13 years of age. If you are younger, please ask your educated persons for advice.
Data privacy statement for the use of LinkedIn
Our website utilizes features of the LinkedIn network. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. A connection to LinkedIn servers is formed for any access to our website that includes functions from LinkedIn. LinkedIn is informed that you visited our website with your IP address. If you click the LinkedIn “Recommend” button and are logged in to your LinkedIn account, LinkedIn is able to connect your visit to our website with you and your user account. We advise you that as the operator of this website, we have no knowledge of the content of the data transmitted to LinkedIn or how it is used.
Privacy Statement for the Use of Twitter
Functions of the Twitter service are integrated on our website. These functions are offered by Twitter Inc., Twitter, Inc. 1355 Market St, Suite 900, San Francisco, CA 94103, USA. Through the use of Twitter and the “Re-Tweet” the web pages your visits are linked to your Twitter account and made known to other users. This data is also transmitted to Twitter.
We point out that we, as providers of the sites, have no knowledge of the content of the transmitted data and use of it through Twitter. For more information, see http in the privacy statement of Twitter: twitter.com/privacy
Your privacy settings on Twitter, you can change the account settings under http://twitter.com/account/settings
Privacy Statement for the Use of Instagram
Functions of the Instagram service are integrated on our website. These functions are offered by Instagram is operated by Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA ("Instagram"). An overview of Instagram buttons and their appearance can be found here: https://help.instagram.com/
When you access a page of our website that contains such a plugin, your browser establishes a direct connection to Instagram's servers. The relevant provider will transmit the content of the plugin directly to your browser and integrate it into the page. Through this integration, the provider will receive the information that your browser has called up the corresponding page of our website, even if you do not have a profile or are not currently logged in. This information (including your IP address) is transmitted directly from your browser to a server of the relevant provider in the USA and stored there.
If you are logged in to the service, the providers can directly map your visit to our website to your profile on Instagram. If you interact with the plugins, e.g. by pressing "Instagram" button, this information will also be transmitted directly to a server belonging to the providers and stored there. The information will also be published on the social network, on your Instagram account, and shown to your contacts.
The purpose and extent of the data collection and the further processing and use of the data by the provider as well as your rights in this regard and the setting options for the protection of your privacy can be found in the privacy policies of the provider.
Pardot Marketing Automation System
We use the Pardot Marketing Automation System of Pardot LLC, 950 East Paces Ferry Road, Suite 3300 Atlanta, GA 30326, USA (“Pardot Marketing Automation System”) on our websites. Pardot Marketing Automation System is a special software for capturing and evaluating movement profiles of website visitors. Provided that Pardot LLC processes personal data, the processing is done exclusively on our behalf and according to our instructions. We have ensured an individual agreement with the Pardot LLC in compliance with the EU Data Protection Directive through the Pardot LLC.
Nevertheless, we preventatively indicate that the Pardot Marketing Automation System uses “cookies”, which are stored on the individual users’ computers and allow analyses of website usage. You may prevent the storage of cookies at any time in the appropriate settings of your Internet browser. Blocking these cookies may however restrict certain functions and usability of our offer.
For the purpose of protection against misuse of our web forms as well as against spam we use the Google reCAPTCHA service as part of some forms on this website. By checking a manual entry, this service prevents automated software (so-called bots) from performing abusive activity on the site. In accordance with Art. 6 (1) Clause 1 lit. f the preservation of our justified legitimate interests in the protection of our website against misuse as well as an interference-free representation of our online presence.
Google reCAPTCHA is an offer from Google LLC (www.google.com).
Google LLC is headquartered in the United States. This country has an adequacy ruling from the European Commission. This goes back to the EU US Privacy Shield, under which Google LLC is certified. A current certificate can be viewed here: https://www.privacyshield.gov/list
1.1.7 Registration for closed user groups
Limited access for special user groups
Specific information such as details on our products we can only share with a limited group of people. Therefore we file the following personal data:
- Name and surname
- User name and password
- E-mail address
We process this personal data in order to provide you with an access to our website. They will be deleted in case you ask us to deactivate your user account.
1.1.8 Information on side effects and quality complaints
Please note that our corporate website is not intended or designed for communications regarding side effects, lack of therapeutic effect, medication errors, grey market products/counterfeit medicine, incorrect or off-label use, quality complaints and/or other issues regarding the safeness or quality of our products. We understand you may wish to report side effects or make a quality complaint. You can do this by either contacting your health care professional (e.g. physician or pharmacist) or your local health authority, or by using the reporting form on our portal dedicated to the reporting of suspected adverse drug. (https://drug-safety.grunenthal.com/ or you may directly contact firstname.lastname@example.org) If you nevertheless report undesirable side effects or other issues regarding the safeness or quality of our products, we will be legally bound to deal with your communication and may have to contact you for clarification purposes. Subsequently, we may have to notify the health authorities and in this context, your information will be forwarded in pseudonymized form, that means no information by which you may be directly identified will be passed on. We may also have to forward these pseudonymized notifications to our group companies and cooperation partners, to the extent these are likewise obliged to notify their respective health authorities.
1.1.9 User Surveys
We sometimes conduct user surveys on our website. Participation is voluntary, of course. We use functional cookies to carry out the user surveys. The technical information recorded by the user survey is the same information that is recorded when users visit the website (see above). Your responses submitted during the user survey will not be linked to your personal data such as your IP address.
1.2 Transfer of data for commissioned processing
We will to some extent use specialized service contractors for the processing of your data. We carefully select and regularly monitor such service contractors. They will only process personal data upon our instruction and strictly in accordance with our directives, based on respective data processor agreements.
1.3 Processing of data outside the EU/the EEA
Your data will partly be processed in countries outside the European Union (“EU”) or the European Economic Area (“EEA”). The respective countries may have a lower data protection level than European countries. In such cases, we will ensure that a sufficient level of protection is provided for your data, e.g. by concluding specific agreements with our contractual partners , or we will ask for your explicit consent to such processing.
2. Information regarding your rights
You have the following rights according to applicable data privacy laws:
- right of information about your personal data stored by us;
- right to request the correction, deletion (provided that we are not legally obliged to keep the data)or restricted processing of your personal data;
- right to object to a processing for reasons of our own legitimate interest, public interest or profiling, unless we are able to proof that compelling, warranted reasons overruling your interests, rights and freedom exist, or that such processing is done for purposes of the assertion, exercise or defense of legal claims;
- right to data portability;
- right to file a complaint with a data protection authority.
- You may revoke your consent to the collection, processing and use of your personal data at any time with future effect. For further information please refer to the chapters above describing the processing of data based on your consent.
If you wish to exercise your rights, please address your request to the contact form or to our company data protection officer whose contact detail you will find below.
Do you have any questions regarding our data privacy? Then please let us know! You can either use our contact form or get in touch with our company data protection team at the following address: email@example.com
Requests and complaints
If, as the data subject, you do not agree with the way in which Grünenthal or persons at Grünenthal process your data and wish to inform the data protection officer directly, please contact him under:
You can only reach our data protection officer at this address. The data protection officer is obliged to keep your identity confidential. Should it come to the conclusion that your identity could be inferred in the course of clarifying a complaint, the data protection officer will point this out to you in advance and, if necessary, ask you to release him from his obligation to secrecy.
Data Protection Supervisory Authority
You may address questions and complaints also to the Data Protection Supervisory Authority in charge:
Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
Postfach 20 04 44
4. Amendment of Privacy Statement
We may update our Data Privacy Statement from time to time and we will publish these updates on our website. They become effective upon publication So we recommend you regularly visit the site to keep yourself informed on possible amendments.
This Data Privacy Statement was last updated on 27 July 2018.