Seagen European Privacy Policy

Effective: 15 November 2021

This Privacy Policy describes the privacy practices of Seagen Inc. and its affiliates in Europe (collectively, “Seagen”, “we,” “us,” or “our”) with respect to the types of personal data and other data we collect from and about you when you interact with us or use our websites, apps, or other services as described in this Policy (collectively, the “Services”) and how we use, store and share the data collected. This Policy applies to the Seagen affiliate sites that link to it. For purposes of the General Data Protection Regulation (EU) 2016/679, Seagen B.V. in Schiphol, The Netherlands, is the data controller.


Data We Collect

We collect personal data and other data from and about individuals who interact with us and use our Services. We collect certain data automatically through an individual’s use of our websites, we collect data that individuals voluntarily provide to us and we collect data about individuals from third-party sources. The data collected and how we use and share it depends on the manner in which individuals interact with us and our Services and the purpose for which it is being collected. We may combine the data we collect from individuals with data we receive from third-party sources.

Types of Data Collected

Following are the categories of personal data, along with some examples of the types of data within each category, that we may collect across the range of ways that individuals interact with us or use our Services, including as healthcare professionals, individuals using or submitting data about our products or Services, clinical trial participants (who will also receive and be asked to consent to a much more detailed data consent document prior to their participation in a clinical trial), job applicants interested in a career with Seagen and website visitors.

Contact data: Email address, mailing address, telephone number, other data that enables us to contact an individual directly.

Identifiers: A real name, alias, unique personal identifier, online identifier, username, Internet Protocol address, account name, driver's license or other government-issued identification number, passport number.

Demographic data: Age, ancestry, national origin, citizenship, religion or creed, marital status, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions).

Health data: Medical conditions and treatment, health insurance data, physical characteristics or description, genetic data (including familial genetic data).

Biometric data: Activity patterns used to extract a template or other identifier, or identifying data, such as fingerprints, faceprints and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns and sleep, health, or exercise data, which allow or confirm the unique identification of an individual.

Content of communications: Data that individuals post on our website or social media pages and data provided through communications with us.

Professional or employment-related data: Current or past job history, salary, skills, curriculum vitae/resumes, educational records, identification documents, work permits.

Technical data and internet or other similar network activity: Device data, browser data, browsing history, search history, data on an individual’s interaction with a website, application, or advertisement.

Geolocation data, including precise geolocation data: Physical location.

Sensory data: Audio, visual, thermal, olfactory, or similar data.

Inferences drawn from other personal data: Profiles reflecting an individual’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities and aptitudes.

Click on the category of individual or type of activity below to learn more about the specific type of data we may collect and the purposes and legal bases for the collection of data related to such categories of individuals and activities.

Healthcare Professionals

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Seagen will electronically process and store the following categories of personal data related to your professional activities in its CRM (Customer Relations Management) system and other systems: personal details (e.g. name, gender, professional registration number), contact details (e.g. email address, telephone number(s), country), professional qualifications, institute and other professional affiliations (e.g. department, function, speciality), data about your professional accomplishments and activities (e.g. publications, any research you may have conducted, whether you treat certain diseases and your treatment preferences), memberships (e.g. boards, committees), opinions about us, our products and services.

Seagen may also process data such as your area(s) of expertise, professional credentials, activities, skills, preferences and professional interests. Seagen may obtain this data from public sources or data brokers, such as IQVIA.

For more information about country-specific transparency notices, please visit this link.

Purpose for Collection and How We Use Your Data as a Healthcare Professional: We will process your data to assess your interest in our products and events, to share scientific data on therapeutic area(s) and products that may be of interest to you, to plan and invite you to scientific meetings and events based on the therapeutic area(s) of your interest, to keep record of our interactions with you, to create statistics and study trends. Depending on your role, we may be required to process your data to ensure treatment access is secured according to Institution-specific criteria.

Legal Basis for Processing Healthcare Professional Data: The processing of your personal data is based on our legitimate interest to contact you as described above, establish a relationship with you and keep track of our interactions with you. When necessary, we will also obtain your consent: for example, for certain direct marketing activities through email or phone. If you are a healthcare professional from Italy, we will obtain your consent for all purposes rather than for only marketing communications.

Data Retention for Healthcare Professional Data: Seagen will review the content of its databases periodically to make sure that data registered therein is up-to-date and still of interest. In most circumstances, your personal data as a healthcare professional will not be kept for longer than five years after our last interaction if we do not have any further interactions. In circumstances where we may have longer retention obligations due to legal or regulatory requirements, we will retain your personal data as set forth below in the general “Data Retention” section.

Your Rights as a Healthcare Professional: You have the rights set forth below in the “Your Privacy Rights” section of this Privacy Policy. Please note that you may lodge a complaint with your country’s Data Protection Supervisory Authority, should you have concerns about the processing of your data by Seagen, as set forth below in the “Your Privacy Rights” section.

European Medical Information and Product Safety Notice

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When a healthcare professional or other individual provides us information about our products that we are required to report pursuant to applicable laws and regulations, Seagen will electronically process and store the following categories of personal data in its systems: personal details (e.g. name, gender, date of birth), contact details (e.g. email address, telephone number(s), country), professional qualifications, institute and other professional affiliations (e.g. department, function, speciality). If you contact us to ask for information on our products or to report an adverse event, we may also collect data about the health or other sensitive data of the patient who is using our product.

Purpose for Collection and How We Use Your Data: This data is only processed when relevant and necessary to properly document a potential adverse reaction and for the purpose of meeting our pharmacovigilance, safety and any other legal requirements.

In case of a medical enquiry, your personal data may be used to answer your enquiry, follow up on said request, provide answers to your request, send requested material and maintain the data in a medical information database for reference.

In case of an adverse event reporting, we may use personal data to get in touch with people who contact us in order to follow up and, if needed, obtain further information, provide information to regulatory agencies and authorities and maintain the data in a medical information database for reference.

In case of communications about our products, the data will be used only for that purpose (e.g. evaluation, classification and assessment of the product complaint, to follow up on such requests, and to maintain the data in a product complaints database for reference).

Legal Basis of Processing: The processing of your personal data will be based on our intent and obligation to ensure high standards of quality and safety of medicinal products. The processing may also be based on your consent to said processing.

Data Sharing: Seagen may also need to share your data with service providers (e.g. medical information call centres). In cases when an adverse event is reported, we will share data with health authorities (such as the European Medicines Agency) to allow them to evaluate adverse events and make efforts to prevent similar events from happening in the future. We may also share data as set forth below in the “Sharing or Disclosing Your Data” section.

Data Retention for Data from Medical Information Enquiries and Product Safety Reports: For adverse reporting, in accordance with law, pharmaceutical companies, as market authorisation holders of products, must retain all product-related documents for at least the time period of the market authorisation, plus ten years following its expiry. Therefore, personal data related to the safety of our products will be retained for this time period.

For medical information enquiries and product complaints, personal data will usually be retained for a maximum of five years from the moment of collection. In circumstances where we may have longer retention obligations due to other legal or regulatory obligations, we will retain personal data as set forth below in the general “Data Retention” section.

Your Rights: You have the privacy rights set forth below in the “Your Privacy Rights” section of this Privacy Policy. Please note that, for legal reasons, we cannot delete data that has been collected as part of an adverse event report unless it is inaccurate. You may lodge a complaint with your country’s Data Protection Supervisory Authority, should you have concerns about the processing of your data by Seagen, as set forth below in the “Your Privacy Rights” section.

Job Applicants

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Seagen will process the personal data that you have submitted in reply to a job application or spontaneously to evaluate your eligibility for roles within our organisation. This data may include your curriculum vitae or resume, address, identification documents, work permits, educational records, experience, skills and work history. If you are short-listed as a candidate, we may be required to process more detailed personal data. We will notify you accordingly and comply with applicable laws with respect to such data.

Legal Basis for Processing. We have a legitimate interest in processing your personal data in order to assess your eligibility and suitability for roles in our organisation.

Data Retention of Job Applicant Personal Data. Seagen will review the content of its databases periodically to make sure that the data registered therein are up-to-date and still of interest. In most cases your personal data will not be kept for longer than 60 months after our last interaction if we do not have any further interactions. In circumstances where we may have longer retention obligations due to legal or regulatory requirements, we will retain your personal data as set forth below in the general “Data Retention” section.

Your Rights as a Job Applicant. You have the rights set forth below in the “Your Privacy Rights” section of this Privacy Policy. You may lodge a complaint with your country’s Data Protection Supervisory Authority, should you have concerns about the processing of your data by Seagen, as set forth below in the “Your Privacy Rights” section.

Data Collected Automatically Through Our Websites

Depending on the cookie settings you select when you visit our websites or use our Services, we may use cookies and other technologies to automatically collect certain technical data, including your network activity, such as your device information, information about the network you use to access the Services, browser type and version, your activities while using the Services, other sites or services previously visited and content you see or click on, as well as other information such as your identifiers (for example, your Internet Protocol address) and your general geolocation data. We use this data to understand and analyse trends, administer the Services, learn about user behaviour and gather demographic data about our users as a whole. For more information about how we and our analytics and other service providers use cookies and other technologies to collect information when you visit our websites, see the “Use of Cookies and Other Technologies” section below.

Data Provided Voluntarily

We collect data voluntarily provided by individuals when they interact with us (such as in person, by phone and through the Services). For example, we collect data provided by:

  • Healthcare professionals who interact with us through a variety of activities, such as meetings, sales calls, scientific exchanges, advisory boards, consulting arrangements, market research, exhibits, presentations, conventions, or in our clinical trials
  • Patients or carers who enquire about our programmes or enrol locally (as allowed by applicable laws)
  • Persons who report an adverse event or product complaint
  • Job applicants who enquire about or apply for a job
  • Investors who contact us or visit our websites
  • Persons who request information about our products and programmes
  • Service providers and business partners with whom we have relationships
  • Other individuals who interact with us in the course of our business

Data from Other Sources

Depending on the interaction or potential interaction that we may have with you, we may obtain different types of data about you from a variety of sources, including:

  • Healthcare organisations
  • Healthcare professionals
  • Professional associations
  • Business partners
  • Research and development partners
  • Clinical trial partners
  • Contract research organisations
  • Patients
  • Carers or guardians
  • Clinical trial/study personnel
  • Data brokers
  • Service providers

Here are some examples of how and why we might obtain personal data from third-party sources:

  • We may obtain personal data about job applicants or others with whom we may do business by obtaining their consent where required and performing reference checks or background screenings.
  • We collect personal data about patients from healthcare professionals and caregivers. For example, in the context of adverse event reporting.
  • In our clinical trials, site investigators share pseudonymised personal data of clinical trial subjects with us and service providers (e.g. laboratories that process biological samples, vendors that provide trial subject randomisation services and trial supplies) to conduct the trials.
  • We buy data to understand attributes about healthcare professionals, such as geography, demographics, needs, specialisation, affiliation, product usage and attitudes.

Purpose for Collection and How We Use Your Data

We use personal data in a variety of ways to conduct our business and pursue our business interests. We use the personal data we collect to:

  • Register and validate users of the Services
  • Communicate with you for marketing and non-commercial purposes
  • Respond to requests and enquiries
  • Process job applications and administer the employment relationship
  • Administer our programmes and process enrolments
  • Conduct clinical trials
  • Conduct research and development
  • Deliver products and services
  • Improve our products and services
  • Provide customer service
  • Provide and gather information about disease states, developments in our therapeutic areas and our products and brands
  • Administer surveys
  • Perform analytics
  • Administer the Services, analyse trends and gather demographic data about users
  • Gain insight on our products, pipeline, strategic planning and unmet medical needs
  • Maintain system security
  • Enter into agreements and enforce contractual rights and obligations
  • Comply with laws and fulfil regulatory obligations (e.g. report on adverse events, process product complaints)
  • Protect our rights and the rights of others

Legal Basis of Processing

In addition to the specific legal bases set forth in the specialised sections of this Policy, the applicable legal bases we rely on to process your personal data for the specific purposes listed in the “Purpose for Collection” section, above, include the following:

  • Our legitimate business interests. For example, to maintain system security, communicate with you at your request, fulfil your information and service requests, conduct surveys, improve our products and services and protect our rights and the rights of others.
  • Performance of a contract with you. For example, when you enrol in a programme, or register for a programme or service.
  • Compliance with laws. For example, to comply with legal and regulatory requirements or respond to a court order or legal request.
  • Consent. We will obtain your consent where we process your personal data and none of the other legal bases stated above would apply to such processing, including for processing activities through our website where we are legally required to obtain consent prior to processing, for marketing communications, where we may collect sensitive data about you, or where you enrol in a service we provide that would require us to obtain your consent. Where we rely on consent to process your personal data, you may withdraw your consent at any time as set forth below in the “Your Privacy Rights” section.

Use of Cookies and Other Technologies

We and our analytics providers use “cookies” and other technologies such as GIF files or web beacons. Cookies are identifiers that facilitate the interaction between your computer or device and the Services. Different types of cookies, such as session and persistent cookies, are used for different purposes. We and our analytics providers may use cookies or other technologies to facilitate site navigation, personalise your experience, perform analytics and remember your data when you use the Services. Data collected through cookies and other technologies may include your Internet Protocol address, geolocation data, device data, browsing activity and search engine referrals. You can manage the collection of location data using your device setting and controls. Please see our Cookies Policy to learn more about cookies and how you can change your preferences.

Sharing or Disclosing Your Data

We may share or disclose personal data to conduct our business and pursue our business interests (see “How We Use Your Data” above). For example:

  • Your personal data may be shared among the European affiliates of Seagen and our other affiliates outside of Europe who assist us in providing our services and conducting our business.
  • We disclose personal data to healthcare professionals, third parties (business partners) and government officials (e.g. law enforcement authorities, the courts, regulatory authorities).
  • We disclose personal data to service providers, suppliers, contractors and affiliates to conduct our business, provide products and services, respond to requests that you make, communicate with you, conduct market research and marketing activities and provide data about products and disease- and health-related topics of interest.
  • We share pseudonymised personal data from clinical trials with research and development partners and consultants to help in the conduct and planning of our clinical trials and products.
  • We also share clinical trial data with government authorities to meet regulatory requirements.
  • We share personal data provided by job applicants with third-party recruiting agencies and platforms that perform services on our behalf.
  • We will disclose personal data if we reasonably believe we are required to do so by law, regulation, or other government authority (such as reporting safety data to the U.S. Food and Drug Administration or the European Medicines Agency), or if we believe it is necessary to protect our company, our website visitors, or others.
  • We may transfer your personal data to a successor entity upon a merger, consolidation, or other corporate re-organisation in which Seagen participates, or to a purchaser of all or substantially all of Seagen's assets who agrees to use your data in accordance with this Privacy Policy.

Processing Location and International Data Transfers

Seagen and its service providers process your personal data in Europe. In addition, Seagen is part of a multinational corporation and, like most other global corporations, will transmit your personal data to our affiliates and service providers located in many countries around the world, including Switzerland, the United Kingdom and elsewhere outside of Europe, where your personal data will be subsequently processed. We may also transfer your personal data to our parent company in the United States, where it will also be processed. Some of the countries to which your personal data is disclosed have not been deemed by the European Commission (“EC”) to provide an adequate level of protection for personal data. When we transfer personal data out of Europe to countries that the EC does not deem adequate, we will implement one or more of the safeguards the EC deems to provide appropriate safeguards, which may include EU Standard Contractual Clauses, transfers to organisations that protect personal data under binding corporate rules, or transfers to organisations that operate under an approved code of conduct or certification mechanism.


When your data is transferred to the U.S., the U.S. (similar to most other countries) has laws that would permit the government to request and obtain access to your data. However, based on historical practice and the nature of the data we maintain, we do not anticipate such requests for your data or the data of other users of our Services.

Regardless of where your personal data is collected or processed, Seagen maintains and requires its service providers to maintain appropriate administrative, technical and physical safeguards to protect data about you.

Minors

Our products, this web site and our other Services are intended for use by individuals who are legally considered to be adults in their jurisdiction of residence. We do not knowingly collect any personal data directly from individuals who have not reached the age of majority (minors).

Links to Third-Party Sites

Some of our websites or interactive features may contain links to third-party websites or services that are not under our control or ownership. Such links do not constitute an endorsement of those third parties or the content displayed therein and you agree that Seagen is not responsible for the content of such websites. We are not responsible for how these sites operate or treat your data. You acknowledge that we provide these links to you only as a convenience and you understand that your data will be used as described by the third parties in their privacy policies.

Data Security and Storage

We implement reasonable technical and organisational security measures that are designed to help protect personal data from accidental or unauthorised access, use, loss, destruction, disclosure, or modification when transmitting or storing personal data. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

Data Retention

We retain data collected for as long as necessary to fulfil the purposes for which the data is collected, as required or permitted by applicable laws, or for other legitimate purposes such as disaster recovery, resolving disputes and enforcing our agreements. In some cases, we anonymise or de-identify personal data so that it can no longer be associated with an individual. In such cases, we may use the anonymised or de-identified data without further notice. The data retention criteria we use for personal data includes considering:

  • The purpose of the personal data collected and the fulfilment of that purpose.
  • The legal basis for which the personal data is processed, e.g. in case of consent, you may be able to revoke your consent.
  • Any legal, contractual, or regulatory obligations we may be under to retain the data.

Your Privacy Rights

You have certain rights with respect to your personal data, subject to the legal obligations and rights of Seagen, including the right to:

  • Request access to your personal data so that you may review it
  • Request correction of the personal data that we have about you
  • Request erasure of your personal data
  • Object to processing of your personal data, including where we are processing your data based on our legitimate interests
  • Withdraw your consent that you have provided
  • Request the restriction of processing of your personal data
  • Request that we provide you or another party a copy of the personal data we have about you in a structured, commonly-used and machine-readable format, subject to certain conditions
  • Request not to be subjected to automated decision-making or profiling

You may exercise your rights via email by contacting dataprotection@seagen.com. We will always endeavour to fulfil your request to exercise these rights, but we may have legal grounds or obligations to reject your request or the inability to fulfil your request, including, for instance, where we do not have direct identifiers, such as with clinical trial data we may process.

We will respond within 30 days after we have verified that you are the data subject or are authorised to make the request on behalf of the data subject. If necessary, we may extend our response time by an additional 60 days to respond properly, but we will notify you if that is the case. If we decide not to fulfil your request, we will tell you the reasons why.

If you disagree with our response to your request, you have the right to lodge a complaint with a data protection regulator in Europe. The contact details of your local supervisory authority can be located here. Should you have any concerns, we request that you contact us first so we can investigate and hopefully resolve, your concerns.

Contact Us For Data Protection Enquiries

Seagen Data Protection Officer
c/o Lucid Privacy Group
1050 Page Street, San Francisco, CA 94117, United States
DPO@seagen.com
+1-415-633-6492

You may also contact our European operations headquarters:

Seagen Data Protection Representative
Seagen B.V.
Evert van de Beekstraat 1-104
1118CL Schiphol
The Netherlands
Phone: +31 20 238 2497
dataprotection@seagen.com

Privacy Policy Updates

We may update this Privacy Policy from time to time. At a minimum, we will post an updated version here. Seagen encourages you to review this Policy regularly for any changes. Any changes will be effective immediately upon posting of the revised Policy, and your continued use of this website or our interactive features will be subject to the then-current Privacy Policy.