The Privacy Policy was Last Updated on August 23, 2023

Please see our Privacy Snapshot (mentioned below) for a high-level overview of our privacy practices.

This Privacy Policy describes the privacy practices of Biocon Biologics Limited and its affiliates and subsidiaries (collectively, “Biocon Biologics”, “we”, “us” or “our”) in relation to personal information that we collect through our websites, applications, services and platforms, our marketing and provisions of products and services, when we offer training or other services to healthcare providers, and through our interactions with you in-person or otherwise (collectively, the “Service” or “Services”). It describes how and why we process your personal information (for example, by collecting it, using it, storing it, or disclosing it to others), and what rights you can exercise in respect of your personal information.

We urge you to carefully read and review this Privacy Policy before accessing or using the Services.

Depending on the way you interact with us, we may provide you additional notices about our processing of your personal information addressing specific processing activities and circumstances. For example, we may provide you a separate privacy notice that will govern the collection, use and disclosure of personal information collected in connection with clinical trials and patient assistance programs.

1. Responsible Biocon Biologics Entity

The Biocon Biologics subsidiary or affiliate with which you interact is the entity responsible for the processing of personal information under this Privacy Policy (as a controller or business, where provided under applicable law). You can find a list of the relevant legal entities responsible for the processing of your personal information at this link: https://www.biocon.com/investor-relations/corporate-governance/corporate-structure/.

2. Personal Information We Collect

Information you provide to us. Depending on your relationship with us and your location, you may provide us with the following categories of personal information:

• Identifiers, such as your first and last name, email and mailing addresses, phone number, healthcare professional information (including professional title, professional certificate, medical license/ registration number, medical specialty, medical society and areas of interest), and the username and password you use to access our Services.
• Commercial information, such as information about the products and services you obtained from us and information contained in invoices.
• Health data, such as conditions with which you have been diagnosed, symptoms that you have experienced after taking a Biocon Biologics product, drug usage, dietary restrictions, and other data relating to your health, which we may collect when you enroll in patient assistance programs.
• Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.

• Usage information, such as information about how you use the Services and interact with us.

• Marketing information such as your preferences for receiving our marketing communications and details about your engagement with them.

• Other information that we may collect which is not specifically listed here, but which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from other sources:

• Public or third-party information sources: We may collect personal information about healthcare professionals who register on our websites from public or third-party information sources to verify professional credentials and identity.
• Social media information. We may maintain pages on social media platforms, such as Facebook, Twitter, and LinkedIn. When you visit or interact with our pages on those platforms, you or the platforms may provide us with information through the platform.

• Other sources. We may obtain personal information from other third parties, such as marketing partners, publicly-available sources, and data providers.

Automatic data collection:

We and our service providers may automatically log and combine information about you, your computer or mobile device, and your interaction over time with the Services, our communications and other online services, such as:

• Device data such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, device identifiers, language settings. and general location information such as city, state, or geographic area.
• Online activity data such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Services, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened or otherwise engage with our communications, such as our marketing emails or clicked links or files within them.

We use the following tools for automatic data collection:

• Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and support our marketing and advertising initiatives.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

For more information on these tools, please read our Cookie Policy.

3. How We Use Personal Information

We use personal information for the purposes described below or as otherwise described at the time of collection. Health data collected in connection with your participation in patient assistance programs is only used to provide you with the Services.

Provide our Services. It is in our legitimate business interests to use personal information to operate, maintain, and provide you with our Services, including registering you for an account on our Services and subsequently providing you with access to scientific and pharmaceutical information on our Services. If we have entered into a contract with you, we will use your personal information as required for us to perform our contractual obligations under the relevant contract.

Communicate with you about our Services. It is in our legitimate business interests to use personal information to respond to your requests, provide support, and communicate with you about our Services, including by sending announcements, updates, security alerts and support and administrative messages.

Improve, monitor, personalize, and protect our Services. It is in our legitimate business interests to improve and keep our Services safe for our users, which includes:

• Understanding your needs and interests, and personalize your experience with the Services and our communications.
• Troubleshooting, testing and research and to keep the Services secure.
• Investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.

Research and development. We may use personal information for research and development purposes in our legitimate business interests, including to analyze and improve the Services and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from personal information we collect. We make personal information into anonymized data by removing information that makes the data personally identifiable to you. We may use this anonymized data and disclose it to third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

Surveys. It is in our legitimate business interest to conduct surveys and collect feedback from you. Where we intend to publish these surveys with information that identifies you, or our surveys or feedback requests will collect sensitive personal information about you (e.g. your racial/ethnic identity or health information), we will ask you for your consent to be able to process this information.

Marketing and advertising:

• Direct marketing. We may send you direct marketing communications about goods, services, and products that we think may be of interest to you as permitted by law, including by email. You may opt-out of our marketing communications as described in the “Opt-out of marketing communications” section below. Where required by law we will only send you marketing information if you consent to us doing so at the time you provide us your personal information.  Otherwise, we will only send you marketing information if it is in our legitimate business interests to send such information.
• Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to display ads around the web. These companies may use cookies and similar technologies to collect information (including the automatically-collected data described above) about your interactions over time across our Services, our communications, and other online services, and use that information to serve online ads that they think will interest you. Where required by law we will undertake such advertising activities on the basis of your consent, otherwise we will do so only if it is in our legitimate business interests to undertake such activities.

Supplier/Partner relationships. Where you are a supplier/partner or a representative of a supplier/partner, it is in our legitimate business interests to use your personal information to contact you and to manage our relationship with you and/or your company. If we have entered into a contract with you/your company, we will use your personal information as required for us to perform our contractual obligations under the relevant contract.

Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes, including to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) audit our internal processes for compliance with legal and contractual requirements and internal policies; (c) enforce the terms and conditions that govern the Services; (d) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and (e) comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities. In these circumstances, we will process your personal information to either to comply with a legal obligation or when it is in our legitimate business interests.

4. How We Disclose Personal Information

We may disclose personal information to the following categories of parties. Health data is only shared with service providers.

Affiliates. We may share your personal information with members of the Biocon Biologics corporate group, including our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate the Services or our business (such as hosting, information technology, support, email delivery and website analytics services).

Advertising partners. Third party advertising companies, including for the interest-based advertising purposes described above.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transfers. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests (including, in connection with a bankruptcy or similar proceedings).

Your instruction or permission. A relevant third party, where you give us permission to do so in the course of your relationship with us from time to time.

5. International Data Transfers

Biocon Biologics operates globally and consistent with applicable laws may process your personal information in jurisdictions that are not regarded as providing the same level of protection to personal information as the jurisdiction in which you are based. In particular, Biocon Biologics will process your personal information in India, the United States and in other jurisdictions where our affiliates or subsidiaries or service providers are located. When transferring personal information across borders, we take steps to put in place safeguards to protect such personal information as required by applicable laws.

These safeguards may include:

• if you reside in the UK or the EEA, relying on a UK government adequacy regulation or adequacy decision by the European Commission;
• entering into agreements that include contractual protections for the transfer of your personal information (such as Standard Contractual Clauses approved by the European Commission and the international data transfer agreement approved by the UK government).

For more information about the safeguards we have in place in relation to the transfer of your personal information, please contact us as set out in the “How to Contact Us” section below.

6. Retention of Personal Information

Where required under applicable laws, we retain personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, any permissions you give us with regards to your personal information, and the applicable legal and regulatory requirements.

7. Privacy Rights and Choices

Opt-out of marketing communications. You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us or by contacting us as provided in the “How to Contact Us” section below. You may continue to receive Services-related and other non-marketing emails.

Limit online tracking. Some internet browsers can be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.

Personal information requests. We offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to personal information:

• Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
• Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
• Correction of personal information that is inaccurate or out of date.
• Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.
• Opt out of the sharing or processing of your personal information for targeted advertising purposes. To exercise this right, you can visit the “Do Not Sell or Share My Personal Information” link in the footer of our website.
• Additional rights, such as to object to our processing of your personal information and request that we restrict our use of your personal information, and where applicable, you may withdraw your consent to our processing of your personal information.
• Right to complain. Depending on where you reside, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred. If you reside in the European Economic Area, click here to find your local supervisory authority, and here if you are in the United Kingdom.

To make a request, please email us or write to us as provided in the “How to Contact Us” section below. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Limits on your privacy rights and choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to Contact Us” section below.

8. Job applicants

When you apply for one of our open positions, we collect the information that you provide in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history, and other information that may be included in a resume. This may also include demographic or diversity information that you voluntarily provide. We may also conduct background checks and receive related information.

We use applicants’ information to facilitate our recruitment activities and process employment applications, including evaluating candidates and monitoring recruitment statistics. We also use successful applicants’ information to administer the employment relationship. We may also use and disclose applicants’ information to improve our websites and for the compliance and protection purposes described above.

Depending on where you are located, we may provide you additional notices about our processing of the information that you provide in connection with your job application.

9. Security

We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.

10. Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions. This Privacy Policy does not apply to such third-party sites or services.

11. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website, or as otherwise required by law.

12. How to Contact Us

If you have any questions or comments about this Privacy Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by email at privacy@bioconbiologics.com or write to us using the following details:

Ethics & Compliance Department
Biocon House, Tower 3, Semicon Park
Hosur Road, Electronics City Phase II
Bangalore-560100, India

Privacy Snapshot

Here is a high-level snapshot of how we collect, use, and share your personal information when you use the Services, but you need to read the entire Privacy Policy for complete information.

*As described further in our Privacy Policy, we may share all categories of personal information with our service providers, affiliates, and professional advisors for the purposes described in the Privacy Policy. We also may share personal information with authorities and others for legal and compliance purposes, and with business transferees in the context of an acquisition or the sale of our business or another corporate transaction.