Privacy Statement for Healthcare Professionals

When do we collect HCP personal information?

• When you interact with PTC staff members or our representatives.
• When you participate in, or request to be considered for PTC-related activities, such as clinical trials, advisory boards, or consultancies.
• When you register for an PTC-sponsored event (including online events); and
• When you contact us for medical information, safety, or quality issues.
• When you interact with PTC or third-party websites or mobile applications (“Apps”) where you have provided personal information in accordance with their respective privacy policies.
• When we send you commercial marketing and medical communications campaigns.

In addition, PTC is regularly provided with professional information about HealthCare Professionals in Europe from a third-party service provider. PTC takes steps to ensure that the information it receives has been collected and transferred in compliance with applicable privacy laws.

Processing of HCP personal information:

PTC may process HCP personal information on one of the following grounds: A) for legitimate business purposes, (B) where HCP has given consent by voluntary providing information, (C) to comply with PTC’s legal and regulatory obligations, and (D) in connection with a contract under which HCP performs.

• PTC’s Legitimate Business Reasons
• PTC’s Professional and Scientific Activities
• Promotion and evaluation of PTC products and services
• Transparency (if applicable)

• Processing activities
• Interaction with PTC personnel
• Ensuring proper data management and handling our Customer Relationships Management
• Participation in professional meetings and conferences
• Response to requests for medical information
• In the event where communication, not based on your consent, of information (e.g. via email) promoting PTC products and services, information and invitations to events or conferences organized by PTC or in which PTC participates, etc.
• Transparency (if applicable) of PTC contributions to your medical education

• Managing and complying with a contract
• Compensation for services or reimbursement for expenses incurred as well as the prevention against fraud, notably, data used to authenticate, data to process payments, verify financial information or facilitate further payments.
• Assist with planning for travel related to PTC activities or products.
• Manage participation in clinical trials, medical research and/or market research.

• Comply with legal and regulatory obligations
• Reporting of adverse events for pharmacovigilance and product complaints.
• Clinical Trials.
• Transparency in the event of a provision provided for by local legislation.
• Tax obligations

• Consent
• Participation in surveys and online services or applications
• Consent granted to our third-party service providers.
• Transparency in the event the transparency is not local legal requirement.
• Where applicable Consent granted for communication of information (e.g. via email or website) promoting PTC products and services, information and invitations to events or conferences organized by PTC or in which PTC participates, etc.

Types of Personal Information collected and processed:

• Name
• Contact information such as address, email, or telephone number
• Your login and password to connect to PTC services online.
• CV and professional information such as areas of specialization
• Your past collaborations with PTC
• Dates and summary of interactions with PTC’s sales representatives or medical staff
• Professional registration number
• Professional and interaction preferences and,
• When necessary to pay for services or reimburse expenses financial and banking information might be collected
• PTC uses collected personal information to better understand professional interests and personalize interactions. PTC might:
• Analyze individual interests, specialty, and preferences
• We may customize the content, communication formats, and offers
• Our goal is to make our interactions more relevant and valuable for your professional needs.

This processing relies on legitimate interests to maintain a strong and meaningful relationships with HCPs we interact

Who can access to Healthcare Professional Data collected?

• Authorized staff from PTC or its representatives acting on PTC’s behalf, subject to applicable privacy laws.
• Regulatory authorities and ethics committees or other third parties pursuant to applicable laws.
• Website and App hosts
• Third parties processing personal information as a data processor under PTC’s instruction (for example, a travel service or a clinical research organization); and
• Third parties with which PTC collaborates (for example, distributors, other members of the healthcare and pharmaceutical industry), but only after taking reasonable steps to ensure that we can share such information in compliance with applicable privacy laws.
• Potential acquirers and other stakeholders in the event of a merger, legal restructuring operation such as acquisition, joint venture, etc.

Where is information processed?

PTC operates in numerous countries including Europe, USA, Japan, Latin America and Canada. Personal data about you may be accessible to PTC headquarters as well as to some PTC affiliates outside European Union (“EU”)/ European Economic Area (“EEA”) or outside of the United Kingdom (UK) and/or Switzerland, and selected vendors and partners, established in the EU, UK, Switzerland or globally. Your personal data may be accessed by staff or suppliers in, transferred to and stored at, a location outside the EU or the EEA or UK or Switzerland in which data protection laws may not afford the same level of data protection as the one in the EU/EEA/UK/Switzerland.

Where PTC processes personal data in countries that may not provide the same level of data protection as in the EU/EEA/UK/Switzerland or in your own country, where you are resident, PTC will implement reasonable and appropriate legal as well as technical and organizational security measures to ensure the security of the processing and in particular to protect your personal data from unauthorized access, use or disclosure including, but not limited to, maintaining binding contractual arrangements with all third parties processing personal data

Retention:

In the context of each activity involving collection, processing, or storage of personal information, we will keep your personal information for no longer than the relevant period necessary for the specific processing purpose(s) for which your information was collected and any other permitted associated purpose. Such retention periods will be shared, as applicable, in the documentation relevant to the activity. Information may be retained for a longer duration where applicable laws or regulations require, or allow, to do so. Information that is no longer needed is either irreversibly anonymized (and the anonymized information may be retained for longer periods) or securely destroyed.

Privacy Rights:

If you wish to access, correct, or delete you r data, please send us your request via email to dataprivacy@ptcbio.com

According to the right to data portability, you have the right to request that your personal information provided to PTC be delivered to you in a structured, commonly used and machine-readable format, subject to certain conditions and can be requested by contacting dataprivacy@ptcbio.com

In case we do not handle your request timely or if you are not satisfied with our response to any exercise of these rights, you are entitled to lodge a complaint with the competent supervisory authority of your place of residence. Further information and contact details of the European competent supervisory authorities can be found here: https://edpb.europa.eu/about-edpb/board/members_en.

Contact PTC Global Privacy and Data Protection Officer:

email: dataprivacy@PTCBio.com