1 Privacy policy

Data protection is a high priority for the management of Geistlich Pharma AG. The Geistlich Pharma AG website can be used without providing any personal data. However, if a data subject wishes to make use of special services of our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we will obtain the consent of the data subject.

The processing of personal data, such as the name, address, e-mail address or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation (GDPR) and in compliance with the Swiss Data Protection Act applicable to Geistlich Pharma AG. The EU recognizes that Swiss data protection law ensures an adequate level of data protection.

By means of this Privacy Policy, our company wishes to inform our users about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of their rights by means of this data protection declaration.

As the controller, Geistlich Pharma AG has implemented numerous technical and organizational measures to ensure that the personal data processed via this website is protected as completely as possible. Nevertheless, Internet-based data transmissions are sometimes subject to security gaps, which means absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

Geistlich Pharma AG stores all personal data in electronic form on servers located in Switzerland. Geistlich Pharma AG will only disclose data abroad if this is necessary for the provision of the service and if the data protection standard of the respective country corresponds to that of Switzerland. If the data protection provisions are not equivalent, Geistlich Pharma AG will conclude a "data processing agreement" with the relevant provider and, if necessary, take any further measures.

The provisions of this Privacy Policy and the Swiss Data Protection Act also apply to the transfer of personal data within Geistlich Pharma AG, but Geistlich Pharma AG is not required to obtain consent for the transfer.

2 Definitions

The data protection declaration of Geistlich Pharma AG is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

We use the following terms, among others, in this privacy policy:

(a) personal data

Personal data is any information relating to an identified or identifiable natural person (hereinafter "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject

Data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.

c) Processing

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of restricting its future processing.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

f) Pseudonymization

Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing

The controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular enquiry in accordance with Union or Member State law shall not be regarded as recipients.

j) third party

A third party is a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or processor, are authorized to process the personal data.

k) Consent

Consent is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

3 Name and address of the controller

The controller within the meaning of the law is Geistlich Pharma AG:

Geistlich Pharma AG
Bahnhofstrasse 40
CH - 6110 Wolhusen
Phone: +41 41 492 55 55

We welcome questions regarding this privacy policy and enquiries about our processing of your personal data to our Data Protection Officer (DPO) by letter or e-mail. Enquiries regarding the processing of your personal data must be accompanied by a copy of the ID or passport identifying the person making the enquiry:

Geistlich Pharma AG
Data Protection Officer (DPO)
Bahnhofstrasse 40
CH - 6110 Wolhusen
dpo@geistlich.com

4 Information you give us

This is information about you that you give us by

§ Filling out forms on our website (or other forms we ask you to fill out and submit),

§ handing us a business card (or similar); or

§ Corresponding with us by telephone, post, email or otherwise.

This may include, for example, your name, address, email address and telephone number, information about your business relationship with Geistlich Pharma AG and information about your professional role, background and interests.

5 Other information

We may also collect some information from other sources. For example:

§ If we have a business relationship with the organization you represent, your colleagues or other business contacts may provide us with information about you such as your contact details or details of their role in the business relationship.

§ Sometimes we collect information from third party providers or publicly available sources for anti-money laundering, background checking and similar purposes to protect our business and comply with our legal and regulatory obligations.

6 Cookies

The Internet pages of Geistlich Pharma AG use cookies. Cookies are text files that are placed and stored on a computer system via an Internet browser.

Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string that allows websites and servers to be assigned to the specific internet browser in which the cookie was stored. This enables the websites and servers visited to distinguish the individual browser of the data subject from other Internet browsers. A specific internet browser can be recognized and identified via the unique cookie ID.

Through the use of cookies, Geistlich Pharma AG can provide the users with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized for the benefit of the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter their access data each time they visit the website because this is taken over by the website and the cookie stored on the user's computer system. Another example is the cookie of a shopping basket in an online shop. The online shop remembers the items that a customer has placed in the virtual shopping basket via a cookie.

When you visit the Geistlich Pharma AG website, you are given the opportunity to choose whether only the cookies required for website operation (required cookies), cookies for analyses (statistics cookies) or all cookies (including marketing cookies) should be set. The necessary cookies help to make our website usable by supporting basic functions such as page navigation and access to secure areas; our website may not function properly if these cookies are not set. Statistics cookies help us to understand how users interact with our website by collecting anonymous information; with this information we can continuously improve our offer. Marketing cookies are used to track visitors to the website; this serves to display relevant adverts that are useful to the individual user and therefore of greater value to the advertising publisher and the third-party provider.

The data subject can also prevent the setting of cookies by our website at any time by means of a corresponding setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.

7 Collection of general data and information

The website of Geistlich Pharma AG collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files.

The following can be recorded

  1. browser types and versions used,
  2. the operating system used by the accessing system
  3. the website from which an accessing system reaches our website (so-called referrer)
  4. the sub-websites that are accessed via an accessing system on our website
  5. the date and time of access to the website
  6. an internet protocol address (IP address),
  7. the internet service provider of the accessing system and
  8. other similar data and information used for security purposes in the event of attacks on our information technology systems.

When using this general data and information, Geistlich Pharma AG does not draw any conclusions about the person concerned.

Rather, this information is required in order to

  1. deliver the content of our website correctly
  2. optimize the content of our website and the advertising for it,
  3. ensure the long-term functionality of our information technology systems and the technology of our website, and
  4. to provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack.

Therefore, Geistlich Pharma AG analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

8 Contact option via the website

The website of Geistlich Pharma AG contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the data controller by e-mail or via a contact form, the personal data transmitted by the data subject will be stored automatically. When using the contact form, you must provide information on title, first name, surname, email, subject and acceptance of the privacy policy. The company can also be specified as an option.

Such personal data transmitted on a voluntary basis by a data subject to the data controller is stored for the purposes of processing or contacting the data subject. This personal data is not passed on to third parties.

9 Registration on our website

The data subject has the option of registering on the controller's website by providing personal data. Which personal data is transmitted to the controller is determined by the respective input mask used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for the controller's own purposes. The controller may arrange for the data to be passed on to one or more processors, such as a parcel service provider, who will also use the personal data exclusively for internal use attributable to the controller.

By registering on the controller's website, the IP address assigned by the data subject's Internet service provider (ISP), the date and time of registration are also stored. This data is stored against the background that this is the only way to prevent the misuse of our services and, if necessary, to enable criminal offences to be investigated. In this respect, the storage of this data is necessary to safeguard the controller. This data is not passed on to third parties unless there is a legal obligation to pass it on or the passing on serves the purpose of criminal prosecution.

The registration of the data subject with the voluntary provision of personal data serves the controller to offer the data subject content or services which, due to the nature of the matter, can only be offered to registered users. Registered persons are free to change the personal data provided during registration at any time or to have it completely deleted from the controller's database.

The data controller shall provide any data subject with information at any time on request as to which personal data relating to the data subject is stored. Furthermore, the controller shall rectify or erase personal data at the request or indication of the data subject, insofar as this does not conflict with any statutory retention obligations. All of the controller's employees are available to the data subject as contact persons in this context.

10 Comment function in the blog on the website

Geistlich Pharma AG offers users the possibility to leave individual comments on individual blog contributions on a blog, which is on the website of the controller. A blog is a portal maintained on a website, usually open to the public, in which one or more persons, called bloggers or web bloggers, can post articles or write down thoughts in so-called blog posts. The blog posts can usually be commented on by third parties.

If a data subject leaves a comment in the blog published on this website, information on the time of the comment entry and the user name (pseudonym) chosen by the data subject are stored and published in addition to the comments left by the data subject. This collected personal data will not be passed on to third parties unless such a transfer is required by law or serves the legal defense of the controller.

11 For applications and in the application process

The controller collects and processes the personal data of applicants for the purpose of handling the application process. Processing may also be carried out electronically. This is particularly the case if an applicant submits relevant application documents to the controller by electronic means, for example by email or via a web form on the website. If the controller concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, unless deletion conflicts with any other legitimate interests of the controller.

12 Use of Google Analytics

Google Analytics uses cookies and generally stores these outside the EU/EFTA area, in particular in the USA. Google uses this information to analyze the use of the website for Geistlich Pharma AG and to compile reports on website activity and internet usage. Furthermore, Google transfers this information to third parties according to its own information, insofar as this is required by law or insofar as third parties process this data on behalf of Google. The IP address transmitted by the browser as part of Google Analytics is not merged with other Google data. Users can prevent the storage of cookies (see "Cookies" above). Users can also prevent the transmission of the data generated by the cookie and related to their use of the website (including IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

13 Use of Google Tag Manager

Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus, for example, integrate Google Analytics and other Google marketing services into our online offering. The Tag Manager itself, which implements the tags, does not process any personal user data. With regard to the processing of users' personal data, please refer to the following information on Google services: https://marketingplatform.google.com/intl/de/about/analytics/tag-manager/use-policy/

14 Use of social plugins

Social network plugins, which are operated exclusively by Facebook, LinkedIn and Instagram, can be recognized by the logo of the respective social network. When you visit a website that has one or more of these plugins integrated, your browser establishes a direct connection with the social network servers. The button is transmitted by the social networks directly to the browser, which integrates it into the website. By integrating the buttons, the social networks receive the information that the corresponding website has been accessed. If the user is logged in to the social networks at the time of their visit, the social networks can assign the visit to the user's account. If the button is clicked, the corresponding information is transmitted directly from the browser to the social network and stored there. The purpose and scope of the data collection, the further processing and use of the data by the social networks as well as the user's rights in this regard and the setting options for protecting the user's privacy can be found in the data protection provisions of the social platforms. The user can prevent the social networks from collecting data about the websites visited by logging out before visiting the website.

a) Facebook pixel, custom audiences and Facebook conversion

Based on our legitimate interests in the analysis, optimization and economic operation of our online offer and for these purposes, the so-called "Facebook pixel" of the social network Facebook, which is operated by Facebook Inc, 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are resident in the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"), is used within our online offer; data is transmitted from you to the USA and, if necessary, to Ireland.

With the help of the Facebook pixel, Facebook is able to determine the visitors of our online offer as a target group for the display of adverts (so-called "Facebook ads"). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (so-called "custom audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and are not annoying. With the help of the Facebook pixel, we can also track the effectiveness of Facebook adverts for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook advert (so-called "conversion").

Facebook processes the data in accordance with Facebook's data usage policy. Accordingly, general information on the display of Facebook ads can be found in Facebook's data usage policy: www.facebook.com/policy.php. Specific information and details about the Facebook pixel and how it works can be found in Facebook's help section: www.facebook.com/business/help/651294705016616.

You can object to the collection by the Facebook pixel and use of your data to display Facebook ads. To set which types of adverts are displayed to you within Facebook, you can go to the page set up by Facebook and follow the instructions there on the settings for usage-based advertising: www.facebook.com/settings. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.

b) LinkedIn Insight Tag

We use components of the LinkedIn network on our website. LinkedIn is a service of LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Each time you access our website, which is equipped with such a component, this component causes the browser you are using to download a corresponding representation of the LinkedIn component.

This process informs LinkedIn which specific page of our website is currently being visited. If you click on the LinkedIn "Recommend" button while you are logged into your LinkedIn account, you can link the content of our pages to your LinkedIn profile. This enables LinkedIn to associate your visit to our pages with your LinkedIn user account.

We have no influence over the data that LinkedIn collects in this way, nor over the scope of this data collected by LinkedIn in the USA. We also have no knowledge of the content of the data transmitted to LinkedIn in the USA. Details on data collection by LinkedIn and your rights and settings options can be found in LinkedIn's privacy policy. You can find this information at www.linkedin.com/legal/privacy-policy.

c) Instagram

The plugin of the social network Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 95025, USA) is used on our website. The Instagram plugin can be recognized by the Instagram symbol on the website. If you click on this symbol while you are logged into your Instagram account, you can link the content of the website to your Instagram profile. This allows Instagram to associate your visit to this website with your user account. As the provider of the site, we have no knowledge of the content of the transmitted data or its use by Instagram. Instagram transfers data to the USA. All further information on Instagram's privacy policy can be found at www.instagram.com/about/legal/privacy

d) YouTube

Our website uses plugins or content from YouTube (belongs to Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA). When you visit our website, a direct connection to the YouTube servers is established via your browser. As a result, the information that you have accessed our website is transmitted to YouTube in the USA. If you are logged into your YouTube account, your visit to our website and all your interactions with the plugin (e.g. clicking on the YouTube button) can be assigned to your YouTube profile and saved on YouTube - even if you do not have a YouTube profile, it cannot be ruled out that YouTube will save your IP address. Please also note YouTube's privacy policy: www.google.com/intl/en/policies/privacy.

To prevent YouTube from collecting data when you visit our website, log out of YouTube before visiting. To prevent YouTube from generally gaining access to your data via websites, you can exclude YouTube plugins with an add-on for your browser (e.g. www.youtube.com/user/disconnecters).

15 Use of Google Maps

The map service Google Maps is used on our website. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. To use the functions of Google Maps, it is necessary to save your IP address. This information is usually transmitted to a Google server in the USA and stored there. The use of Google Maps is in the interest of an appealing presentation of our online offer and to make it easy to find the places we have indicated on the website. You can find more information on data protection at Google under the following link policies.google.com/privacy.

16 Use of Hotjar

Hotjar Ltd, Dragnoara Road, Paceville St. Julian's STJ 3141, Malta is an online tool that is used to analyze traffic and provide visitor feedback. The aim is to optimize the conversion rate and better understand visitor behavior.

Hotjar's privacy policy can be viewed at the following link www.hotjar.com/legal/policies/privacy/.

17 Use of Cloudflare

We use Cloudflare on our website. This is a US company headquartered at 101 Townsend St., San Francisco, CA 94107, which provides services to improve the security and performance of our website. Data is transferred to the USA. Cloudflare's privacy policy is available at www.cloudflare.com/de-de/privacypolicy/.

18 Use of JSDelivr

We use JSDelivr on our website, which is a content delivery network (CDN) that delivers data to websites. It is a scalable memory erasure service that can be used to deliver static content. The content is therefore not loaded from your own website, but from external servers. This has the main advantages of improving the speed and availability of the required content. JSDelivr is mainly sponsored by Cloudflare and other companies. JSDelivr's privacy policy is available at www.jsdelivr.com/terms/privacy-policy-jsdelivr-net.

19 Disclosure of personal data

Your personal data will not be transferred to third parties, e.g. IT service providers, logistics companies or other processors, for purposes other than those listed below. We only pass on your personal data to third parties if:

§ you have given your express consent to this,

§ this is necessary for the establishment, exercise or defense of legal claims and there is no reason to assume that you have an overriding legitimate interest in the non-disclosure of your data,

§ in the event that there is a legal obligation for the disclosure, and if

§ this is legally permissible and necessary for the fulfilment of contractual relationships with you.

20 Rights of the data subject

If you wish to exercise any of the following rights, please contact us as set out in paragraph 3.

You can also lodge a complaint about our processing of your personal data with the Federal Data Protection and Information Commissioner (FDPIC, www.edoeb.admin.ch).

a) Right to confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

b) Right to information

Any person affected by the processing of personal data has the right, granted by the European Directive and Regulation, to obtain information free of charge at any time from the controller about the personal data stored about him/her and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information

§ the purposes of the processing

§ the categories of personal data being processed

§ the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations

§ where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period

§ the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing

§ the existence of the right to lodge a complaint with a supervisory authority

§ if the personal data are not collected from the data subject: All available information about the origin of the data

§ the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

§ Furthermore, the data subject has a right to information as to whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards in connection with the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.

c) Right to rectification

Any person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to demand the immediate correction of incorrect personal data concerning them. Taking into account the purposes of the processing, the data subject shall also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

d) Right to erasure (right to be forgotten)

Any person affected by the processing of personal data has the right, granted by the European legislator, to obtain from the controller the erasure of personal data concerning him or her without undue delay where one of the following grounds applies and insofar as the processing is not necessary.

§ The personal data have been collected or otherwise processed for such purposes for which they are no longer necessary.

§ The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) GDPR, or point (a) of Article 9(2) GDPR, and where there is no other legal ground for the processing.

§ The data subject objects to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21 (2) GDPR.

§ The personal data have been processed unlawfully.

§ The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject

§ The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

§ If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Geistlich Pharma AG, he or she may, at any time, contact any employee of the controller. An employee of Geistlich Pharma AG shall promptly ensure that the erasure request is complied with immediately.

If the personal data has been made public by Geistlich Pharma AG and if our company is obliged to erase the personal data in accordance with Art. 17 para. 1 GDPR, Geistlich Pharma AG shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform other data controllers who process the published personal data, that the data subject has requested the erasure of all links to this personal data or of copies or replications of this personal data from these other data controllers, insofar as the processing is not necessary. An employees of Geistlich Pharma AG will arrange the necessary measures in individual cases.

e) Right to restriction of processing

Any person affected by the processing of personal data has the right, granted by the European legislator, to obtain from the controller restriction of processing where one of the following applies.

§ The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.

§ The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.

§ The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims

§ The data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

§ If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Geistlich Pharma AG, he or she may at any time contact any employee of the controller. The employee of Geistlich Pharma AG will arrange for the restriction of processing.

f) Right to data portability

Any person affected by the processing of personal data has the right, granted by the European legislator, to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format. He or she also has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to point (a) of Article 6(1) GDPR or point (a) of Article 9(2) GDPR or on a contract pursuant to point (b) of Article 6(1) GDPR and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, when exercising their right to data portability in accordance with Art. 20 para. 1 GDPR, the data subject has the right to obtain that the personal data be transferred directly from one controller to another controller, insofar as this is technically feasible and provided that this does not adversely affect the rights and freedoms of other persons.

In order to assert the right to data portability, the data subject may at any time contact any employee of Geistlich Pharma AG.

g) Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) GDPR. This also applies to profiling based on these provisions.

Geistlich Pharma AG shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

If Geistlich Pharma AG processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This also applies to profiling insofar as it is associated with such direct advertising. If the data subject objects to Geistlich Pharma AG to the processing for direct marketing purposes, Geistlich Pharma AG will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by Geistlich Pharma AG for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact any employee of Geistlich Pharma AG or another employee directly. The data subject is also free, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using technical specifications.

h) Automated decisions in individual cases, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is based on the data subject's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, Geistlich Pharma AG shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the controller.

i) Right to withdraw consent under data protection law

Any person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to withdraw consent to the processing of personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the controller.

21 Data protection for applications and in the application process

The controller collects and processes the personal data of applicants for the purpose of handling the application process. Processing may also be carried out electronically. This is particularly the case if an applicant submits the relevant application documents to the controller by electronic means, for example by e-mail or via a web form on the website. If the controller concludes an employment contract with an applicant, the data transmitted will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, unless deletion conflicts with any other legitimate interests of the controller.

22 Legal basis of the processing

Art. 6 I lit. a GDPR serves our company as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the fulfilment of a contract to which the data subject is a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of another service or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of enquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as for the fulfilment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may become necessary in order to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured on our premises and their name, age, health insurance details or other vital information would have to be passed on to a doctor, hospital or other third party. The processing would then be based on Art. 6 I lit. d GDPR. Ultimately, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not prevail. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 Sentence 2 GDPR).

23 Legitimate interests in the processing pursued by the controller or a third party

Where the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is to carry out our business in favor of the well-being of all our employees and our shareholders.

24 Legal or contractual provisions for the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision

We inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded for a data subject to provide us with personal data that must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences would be if the personal data were not provided.

25 Existence of automated decision-making

As a responsible company, we do not use automated decision-making or profiling.

26 Data security

We use the widespread SSL/TLS (Secure Socket Layers or Transport Layer Security) method in conjunction with the highest level of encryption supported by your browser when you visit our website.

We also use suitable technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

27 Updates and amendment of this privacy policy

It may become necessary to amend this privacy policy as a result of the further development of our website and services or due to changes in legal or official requirements.

You can call up and print out the current data protection declaration at any time on our website.

This privacy policy is currently valid and was last updated in February 2024.