CONTENTS

1. INTRODUCTION
2. WHO PROCESSES YOUR DATA
3. WHAT PERSONAL DATA DO WE PROCESS?
4. FOR WHAT PURPOSES WE PROCESS YOUR DATA
5. HOW YOUR DATA IS PROCESSED
6. HOW LONG WE PROCESS YOUR DATA
7. TO WHOM YOUR DATA IS COMMUNICATED OR TRANSFERRED
8. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?
9. CHANGES TO THIS PRIVACY POLICY

1) INTRODUCTION

This document describes how the website https://eligard.co.uk (hereinafter “Site”) is managed, with reference to the processing of the personal data of users who visit it. The Site is a promotional website operated by Recordati Pharmaceuticals Ltd registered in England and Wales under company number 05421174 with our registered office at Breakspear Park, Breakspear Way, Hemel Hempstead, Hertfordshire, HP2 4TZ, our VAT number is GB863437017 (referred to as “Recordati”, “we”, “us”), in its capacity as data controller. Its content is addressed only to Healthcare Professionals.

When you browse our Site, interact with us, or use our services (“Services”), we may collect information and personal data about you. For this reason, in accordance with the provisions of UK General Data Protection Regulation (Regulation (EU) (2016/679) (‘UK GDPR’) and the Data Protection Act 2018 (‘the Act’), we have created the following document (hereinafter “Privacy Policy”) in order to describe what personal data we collect, the purposes and methods of processing it and the security measures we take to protect it.

This Privacy Policy constitutes the information that is provided pursuant to Art. 13 et seq. of and exclusively concerns the Site and the processing of data by Recordati. Any third-party websites referred to on this Site, including through links, are not covered by the information indicated in this Privacy Policy.

2) WHO PROCESSES YOUR DATA

The data controller is Recordati Pharmaceuticals Ltd, part of the Recordati Group.

The Data Protection Officer of the Recordati Group can be contacted at the following email address: groupDPO@recordati.com.

3) WHAT PERSONAL DATA DO WE PROCESS?

Α. Depending on the nature of our relationship and/or interaction(s), we may collect and process Personal Data about you, by electronic or other means, including:

• Information you give us about you in the following cases:
  • When you declare that you are a Healthcare Professional, in order to access the site; and/or
  • When you contact us by corresponding with us through e-mail to report an adverse event and/or a product complaint (at the respective email address of the medical information department available on each page) and choose to provide personally identifiable information. The information you give us are mainly contact details and may include, your name, address, e-mail address and phone number, as well as expertise area and relationship with the patient.

We will use the collected data for the purpose for which you provided it to us, such as to respond to your inquiry or to provide you with information that you have requested.

• Information we collect about you. With regard to each of your visits to our Site we will automatically collect the following information:
  • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time), listening data (descriptions of the title, segments included in a resource, time and date stamps for download material and playback events, session IDs and information about the device or platform used to download or play a particular file); page response times, download errors, duration of page visits, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.

Β. In some cases, we collect personal data about a patient in relation to a reported adverse event associated with that patient via the Healthcare Professionals that visit such Site and contact the Medical Information department through e-mail (at the respective email address of the medical information department available in “Get in touch”) to report such events. The personal data that we collect may be limited by national laws, but may include:

• Identifiable Data: initials or name and last name, age or date of birth;
• Biometric data: weight and height;
• Details of the product associated with the adverse event (including the dosage taken or prescribed, the reason for being prescribed the product and any subsequent change to the patient’s usual regimen), details of other medicines or remedies the patient is taking or was taking at the time of the adverse event, (including the dosage, the length of time the patient was taking the other medicine, the reason the patient was taking that other medicine and any subsequent change to the patient’s regimen), details of the adverse event experienced such as the outcome, causality, etiology and diagnosis, the treatment the patient received for that adverse event, and any long-term effects the event has had on the patient’s health;
• Medical data: information considered relevant, including risk factors and pregnancy and medical history or familial history considered relevant, including documents such as laboratory reports, medication histories and patient histories.

Recordati is required by law to conduct follow-up enquiries on reported adverse events. We must therefore keep sufficient information about reporters (Healthcare Professionals) to allow us to contact them for additional information once we have received the adverse event report, as mentioned under section A. above.

4) FOR WHAT PURPOSES WE PROCESS YOUR DATA

• We will collect and process your Personal Data for one or more the following purposes to: To provide you with the information, products and services that you request from us;
• To support you access the collected resources and material as well as to listen or download the recorded videos and uploaded guides and booklets and other pdf material that might interest you;
• To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
• To notify you about changes to our service;
• To ensure that content from our Site is presented in the most effective manner for you and for your computer.
• To comply with legal or regulatory obligations and the directions of law enforcement agencies and court orders, such as in relation to reporting for the safety of information and product quality complaints. As part of our safety reporting obligations, we may use reporter’s personal data to investigate the adverse event, contact reporters for further information about the adverse event reported and process and analyze adverse event information received by Recordati UK LTD to support safety monitoring of the product, as well as report the adverse event to the respective regulatory authorities.
• To administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• To improve our Site to ensure that content is presented in the most effective manner for you and for your computer;

• To get to know our users through the use of cookies and similar tracking technologies. The use of cookies and similar technologies allows us to recognize you when you return to our Site. For more information visit our Cookie Policy.

• 
  
  • As part of our efforts to keep our Site safe and secure.

We shall not use your Personal Data for purposes other than the ones specified herein without providing you with prior notification and obtaining your specific consent, where necessary.

The legal grounds for processing your Personal Data for the above-mentioned purposes are the following:

• we may process your Personal Data after obtaining your consent, such as for direct marketing and promotional purposes. This consent may be withdrawn by you at any time without giving any Please note that the withdrawal of consent will not affect processing by us which has already occurred up to the date of withdrawal.
• we may process your Personal Data if necessary, to comply with a legal obligation to which we are subject to, such as our safety reporting and transparency
• we may process your Personal Data if required for the performance of a contract with you (e.g. consulting; speaker agreement).
• we may process your Personal Data, relying on Recordati’s overriding legitimate interests and as permitted under applicable legislation, e.g., conducting professional relationships and operations including strategy and marketing activities; communicating with you about our products and services when you expect to do so; building your professional profile to develop and maintain a current or potential collaboration with you.

5) HOW YOUR DATA IS PROCESSED

Your personal data may be processed by electronic and/or paper means.

The security of your personal data is important to us. We adopt – and request our service providers to adopt – appropriate technical and organizational security measures to prevent the loss or destruction, even accidental, of data, illicit or incorrect use and unauthorized access to data, in compliance with applicable legislation. In addition, the IT systems are configured in such a way that personal and identification data are used only when necessary to achieve the specific processing purposes pursued from time to time.

We implement multiple security technologies and procedures to protect your personal data from the risks described above. However, we would like to point out that electronic transmissions or storage of information are not 100% secure. Therefore, despite the security measures we have put in place to protect your personal data, we cannot guarantee that data loss, misuse or alteration will never occur.

We do not use automated individual decision-making that would have legal effects on you or, similarly, significantly affect you.

6) HOW LONG WE PROCESS YOUR DATA

Personal data is processed for the time necessary to provide the requested information or Services and, in any case, in accordance with any applicable legal or regulatory obligations. Notably:

• We process your registration data until your request for deletion or the termination of the relationship between us and our business partners/affiliated companies.
• If you receive communications by email, we process your personal data until the relationship between us and our business partners/affiliated companies ends or until you request deletion or objection to processing. You can exercise your rights at any time. More information can be found in section 8 below.
• If you send us questions or requests, we process your personal data for as long as necessary to respond to you and comply with your request.
• For information on the storage of cookies and other technologies, please visit our Cookie Policy.

7) TO WHOM YOUR DATA IS COMMUNICATED OR TRANSFERRED

Your personal data will be processed by our duly authorised staff, based on their respective needs. Your data will also be processed by our suppliers for technical and organizational services functional to the processing purposes indicated above, such as providers for maintenance services for the Site and hosting services. They act as our data processors on the basis of our instructions and in accordance with the provisions of the contracts they have entered into with us.

We may disclose your personal data to public authorities or bodies and to any other legitimate recipient in accordance with the law. In this case, the recipients will act as independent data controllers according to their respective institutional purposes.

If we are involved in a reorganization, acquisition, or sale of our company or parts of it, we will disclose your personal data to the third parties involved in the process, in accordance with applicable law. Any third party that is the recipient of your personal data as part of this procedure may only use it within the limits established by this Privacy Policy and applicable legislation.

To receive the updated list of recipients of your personal data, you can contact us using the contact details indicated above.

If your data is transferred abroad to countries that do not provide the same level of data protection as your country, we will ensure that the transfer is carried out in accordance with applicable law, i.e. by obtaining your consent, when necessary, or by taking any other measures necessary to ensure equivalent protection of the data being transferred, including, but not limited to, to implementing the EU Standard Contractual Clauses which may require the recipient to put in place supplementary measures to ensure an essentially equivalent level of protection is provided, as in the EU/EEA, the UK or Switzerland. We will ensure that your rights and an adequate level of protection essentially equivalent to that ensured within the EU/EEA, UK and Switzerland are guaranteed. If you would like to receive a copy of these safeguards, please contact us using the contact details set out in section 2 of this Privacy Policy. At this time, your personal data is not transferred outside the European Union.

8) WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

In accordance with the applicable legislation on the protection of personal data, you may at any time request access to your personal data, verify its accuracy or request that it be corrected or updated.

You may also request the erasure of personal data concerning you, as well as the restriction of the processing of the same, in the cases provided for by the law, and you may object in any case to the processing of your data, on the basis of reasons related to your particular situation, unless we demonstrate the existence of compelling legitimate grounds for the processing of the data by us or as otherwise established by the applicable legislation on the protection of personal data.

You may object to the processing of your personal data at any time in the case of processing for direct marketing purposes.

You can also request the portability of your data, i.e. to receive such data in a structured, commonly used and machine-readable format, and the transmission of your data to another data controller without hindrance from us.

Finally, you can withdraw your consent to the processing of your personal data, if given, at any time.

To exercise the rights mentioned above, you can contact Recordati or the Data Protection Officer of the Recordati Group at the addresses indicated in section 2 of this Privacy Policy.

Finally, you may lodge a complaint with the competent supervisory authority or contact the authority if the exercise of your rights is subject to delay, limitation or exclusion by the data controller.

The contact details of the UK Information Commissioner (ICO) can be found here https://ico.org.uk/make-a-complaint/, for EU national supervisory authorities can be found here https://www.edpb.europa.eu/about-edpb/our-members_en and of the Swiss Federal Data Protection Authority (FDPIC) can be found here https://www.edoeb.admin.ch/en/contact-2.

9) CHANGES TO THIS PRIVACY POLICY

We may update and amend all or part of this Privacy Policy at any time. The version published on the Site is the version currently in force. In the event of a change in the text of this Privacy Policy, we will inform you of such changes with a specific banner, link or pop-up on the home page of the Site or through a dedicated email.

Last Updated July 2026