Privacy Notice

Definitions provide the meanings of the words and expressions that are capitalized and used frequently in this Privacy Notice, such as:

Data Subject is a natural person about whom Acino has got information or data enabling to identify the natural person. Data Subjects are, for example, clients, visitors and the representatives of the partners.

Privacy Notice is this text which sets out the principles for Personal Data Processing by Acino.

Personal Data is any information concerning an identified or identifiable natural person, for example name, e-mail address, phone number, IP address etc.

Personal Data Processing is any operation or set of operations which is performed on the Personal Data of a Data Subject, for example collecting, storing, changing, deleting etc.

Partner is any natural or legal person that uses or has expressed a desire to use the services of Acino or cooperate with Acino.

Visitor is any person using the Website of Acino.

Website means the websites of Acino, such as https://acino.swiss and other connected Acino’s websites, not including links to third-party websites (such as social media platforms).

Services are services and products provided by Acino.

Cookies are the data files sometimes recorded in the device of a Visitor of the Website.

Acino means Acino International AG and any other subsidiary company of Acino International AG.

General Provisions tell you who the controller of Personal Data is and when the Privacy Notice applies.

Acino is legal person Acino International AG, registered address Thurgauerstrasse 36/38, CH-8050 Zurich and its subsidiaries.

Acino may process Personal Data as:

1. a controller, while determining the purposes and means of processing;
2. a processor in accordance with the instructions from the controller; and
3. a recipient to the extent to whom the Personal Data are transferred.

The rights and obligations set out in the Privacy Notice shall be followed by all the employees and cooperation partners of Acino who come into contact with the Personal Data that are in the possession of Acino.

The Privacy Notice may supplement the privacy statements published on the Website or in the devices, and the Privacy Notice may also be amended and supplemented by the same.

Here you find the principles that are always followed by Acino while Processing your Personal Data.

Acino shall always take into account the interests, rights and freedoms of Data Subjects. The objective of Acino is to Process Personal Data responsibly, based on the best practice, with the aim of always being prepared to demonstrate the conformity of Personal Data Processing to the established purposes.

All the processes, guidelines, operations and activities of Acino that are related to Personal Data Processing are based on the following principles:

1. Lawfulness. There is always a legal basis for the Processing of Personal Data, i.e. legal obligation of Acino, contract or consent;
2. Fairness. Personal Data Processing shall be fair, while providing a Data Subject with sufficient information and communication on how the Personal Data is Processed
3. Transparency. Personal Data Processing shall be transparent for the Data Subject;
4. Purposefulness. Personal Data shall be collected for legitimate purposes that have been established precisely and clearly, and shall not later be processed in any manner which is in conflict with these purposes. A Data Subject will always be able to examine the established purpose of Processing for a specific purpose;
5. Minimization. Personal Data shall be adequate, relevant and limited to what is necessary for the purpose of Processing the given Personal Data. Acino  shall be guided by the principle of minimum Processing in Personal Data Processing, and as soon as the Personal Data are no longer necessary or are no longer needed for the purposes for which they were collected and there is no legal obligation for Acino to keep the Personal Data, the Personal Data shall be deleted or archived;
6. Accuracy. Personal Data shall be correct and shall be updated as necessary, and all reasonable measures shall be taken to ensure that Personal Data which is incorrect in the light of the purpose of Personal Data Processing shall be deleted or corrected without delay;
7. Limit of storage. Personal Data shall be stored in the format enabling the identification of Data Subjects only as long as it is necessary to achieve the purpose for which the Personal Data is processed. It means that in case Acino wishes to store the Personal Data for a longer period of time than necessary for the purpose of collecting the data, Acino shall anonymize the data in such manner that the Data Subject shall no longer be identifiable. Acino shall store the data that has been received by Acino via a client relationship or any other similar relationship, in accordance with the law. The data processed under the basis of consent will generally be retained by Acino until consent is withdrawn.
8. Reliability and confidentiality. Personal Data Processing shall be carried out in the manner ensuring the adequate security of Personal Data, including their protection against unauthorized or unlawful Processing and against accidental loss, destruction or damage, by taking reasonable technical or organizational measures. Acino has internal guidelines, rules for the employees, and separate agreements with every processor, stipulating the best practices, on-going risk assessment and adequate technical and organizational measures for Personal Data Processing;
9. Data protection by design and by default. Acino shall ensure that all the systems used shall meet the required technical criteria. The suitable data protection measures have been planned upon the renewal or design of every information or data system (e.g. the information systems and business processes are constructed using pseudonymization and encryption).
   Upon Personal Data Processing Acino shall act with the purpose of always being capable of evidencing the conformity to the aforesaid principles and additional information regarding the conformity to these principles can also be requested from Acino.

Each time you visit Acino Website, general information is gathered automatically and information such as the name of your Internet Provider, your visiting website address, a history of the Acino pages that interest you and your IP address may be stored.

This information is analyzed anonymously and is used to improve our Website’s attractiveness, content and functionality for your convenience.

Acino collects, inter alia, the following types of Personal Data:

1. the Personal Data disclosed to Acino by the Data Subject;
2. the Personal Data generated as a result of the day-to-day communication between the Data Subject and Acino;
3. the Personal Data manifestly made public by the Data Subject (e.g. in social media);
4. the Personal Data generated as a result of visiting and using the Website (e.g. the time spent on the Website);
5. the Personal Data received from third persons;
6. the Personal Data created and combined by Acino (electronic correspondence or communication history in the context of a client relationship).

Acino cooperates with natural and legal persons in many different jurisdictions, to whom Acino may need to transfer data regarding the Data Subjects, including their Personal Data, in the context and for the purposes of co-operation.

Acino maintains data bases in different jurisdictions. Acino may transfer personal data to data bases in a country other than the country of residence of the Data Subject. Even if personal data is transferred to countries that do not mandate compliance with international privacy standards, Acino strives to ensure that the transmission of Personal Data to such countries is secure.

Acino may need to transfer Personal Data to third persons such as public authorities (for example Data Protection Authorities); also advertising and marketing partners, companies carrying out client satisfaction surveys, debt collection agencies, IT partners, persons, authorities and organizations intermediating or providing (electronic) mail services, provided that:

1. the respective purpose and the Processing are lawful;
2.  the Personal Data Processing is carried out in accordance with the guidelines of Acino and on the basis of a valid agreement.

Acino’s maintains a list of the co-operation partners, but due to the obligation to professional confidentiality, it is not disclosed on this Website.

Acino shall transfer Personal Data to outside the European Union only:

1. if there is sufficient protection in the respective country and mainly to subsidiaries of Acino;
2. if protection measures have been agreed upon (e.g. Acino has established intra group data sharing agreement that includes Standard Contractual Clauses approved by EU Commission);
3. the Data Subject has given a clear and informed consent for such transfer;
   the transfer is clearly required by an agreement entered into with the Data Subject;
4. it is necessary for protecting the legitimate interests of Acino  which are not overridden by the interests, rights or freedoms of the Data Subject, and if all the circumstances related to the transfer have been assessed and suitable protection measures  have been established to protect the Personal Data, or if there is some other legal basis therefore.

Acino shall inform relevant Data Protection Authorities of the transfer based on a legitimate interest.

Acino will not sell, transfer or distribute Personal Data to third parties, other than in cases described within this Privacy Notice.

Acino has established guidelines and procedural rules for ensuring the security of Personal Data by both organizational and technical measures. For the same purpose Acino follows corresponding guidelines of EU data protection authorities.

In case of an incident related to Personal Data, Acino shall take all necessary measures to mitigate the consequences and hedge any relevant risks in the future. Inter alia, Acino shall register all the incidents and shall inform relevant Data Protection Authorities and the Data Subject directly (e.g. by email) or in public (e.g. via the news) in prescribed cases.

To ensure confidentiality and the security of Personal Data, recorded online by Acino, Acino uses leading-edge data networks including state-of-the-art firewalls and password protection. Although Acino cannot absolutely guarantee that data will never be lost, misused or changed, all efforts are made to ensure that this is never the case.

Country-specific pharmaceuticals laws may require that certain information be restricted to qualified professionals only. As a result, to be granted registration for access to the password protected areas of the Website requires disclosure of personal data, such as one’s first name, family name, address, e-mail address and additional data which may be disclosed voluntarily. Such data can be viewed, changed and deleted by a registered Website Visitor at any time. We only collect data provided by the Visitor voluntarily. This data will not be relayed to third parties for commercial use but will only be used to improve our service to you, or be used to contact you. Every Visitor can revoke the future use of Personal Data at any time.

Acino stores Personal Data according to applicable legal requirements and to the highest ethical reporting and documentation standards.

Acino shall Process Personal Data only on the basis of lawful grounds, e.g. consent, contract or legal obligations of Acino. Legal bases for Processing of Personal Data include but are not limited to legitimate interests, laws and regulations or an Agreement between the Data Subject and Acino.

Acino shall Process Personal Data on the basis of consent precisely within the limits, to the extent and for the purposes determined by the Data Subject. As for consents, Acino shall follow the principle that each consent shall be clearly distinguishable from other matters, in an intelligible and easily accessible form, using clear and plain language. Consent may be given in writing or by electronic means or as an oral statement. A Data Subject shall give the consent freely, specifically, informedly and unambiguously, for example by ticking a box on the Website. On the basis of Consent, Acino Processes Personal Data, for example if the Data Subject wishes to subscribe to the newsletter, such Consent is for an indefinite period and is valid until the Data Subject has withdrawn it.

Upon entry into and performance of an agreement, Personal Data Processing may be additionally provided for in the specific Agreement, but Acino may Process Personal Data for the following Purposes:

1. in order to take steps at the request of the Data Subject prior to entering into the agreement;
2. to identify the Partner to the extent required by due diligence;
3. to perform the obligations to the Partner regarding the provision of its Services;
4. to communicate with the Partner and/or Visitor;
5. to ensure the performance of the payment obligation of the Partner;
6. to submit, realize and defend claims.

An Agreement may be entered into on behalf of the Data Subject, or in the name of the Data Subject, by a legal entity.
When processing on the basis of the Agreement, depending of content of the Agreement we will retain Personal Data after the expiry of the Agreement until the deadlines specified in the relevant legislation.

For the entry into an employment agreement, the Processing of the Personal Data of a job applicant by Acino based on the entry into the agreement and legitimate interest shall include:

1. Processing of the data submitted by the job applicant to Acino for the purpose of entering into an employment agreement;
2. Processing of the Personal Data received from the person indicated as the referee by the job applicant;
3. Processing of the Personal Data collected from state databases and registers and public (social) media.

Legitimate interest means the interest of Acino in the management and direction of its business in order to be able to offer the best possible Services on the market. Acino shall Process Personal Data on a legal basis only after careful consideration in order to ascertain the legitimate interest of Acino, based on which the Personal Data Processing is necessary and is in compliance with the interests and rights of a Data Subject. In particular, Personal Data Processing may take place on the basis of a legitimate interest for the following purposes:

1. for ensuring a trust-based relationship with a Partner, for example Personal Data Processing that is strictly necessary to determine the ultimate beneficiaries or to prevent fraud;
2. for the identifiers and Personal Data collected upon the use of Websites, mobile applications and other Services. Acino shall use the collected data for web analysis or for the analysis of mobile and information society services, for ensuring and improving the functioning, for statistical purposes and for analyzing the behaviour and using experience of Visitors and for providing better and more personalized Services;
3. for the organization of campaigns, including organization of personalized and targeted campaigns, carrying out Partner and Visitor satisfaction surveys, and measuring the effectiveness of the performed marketing activities;
4. for analysing the behaviour of the Partner and Visitors on Websites; for network, information and cyber security considerations, for example for fighting against piracy and for ensuring the security of the Websites, as well as for the measures taken for making and storing backup copies;
5. for corporate purposes, in particular for the financial management and for transferring Personal Data within the group for internal administrative purposes, including the Processing of the Partner’s or employees’ Personal Data. Such Processing of Personal Data takes place, in particular, with the exchange of data between offices in Acino Group;
6. for the establishment, exercise or defence of legal claims.

For performing a legal obligation, Acino shall Process Personal Data to perform the obligations set forth by law or to exercise the uses permitted by law. Legal obligations derive, for example, from pharmacovigilance and employment regulations.

In case Personal Data Processing is carried out for a new purpose, different from those for which the Personal Data were originally collected, or is not based on the consent given by the Data Subject, Acino shall carefully assess the permissibility of such new Processing. The new purposes of processing are always thought through. In order to determine whether the Processing for the new purpose is in compliance with the purpose for which the Personal Data were originally collected, Acino shall take into consideration, inter alia, the following:

1. any link between the purposes for which the Personal Data were collected and the intended further purposes Processing;
2. the context of collecting the Personal Data, in particular regarding the relationship between the Data Subject and Acino;
3. the nature of the Personal Data, in particular whether any special categories of Personal Data, or Personal Data related to criminal convictions and offences are processed;
4. possible consequences of the intended further processing for the Data Subjects;
5. existence of appropriate protection measures.

If a Visitor discloses personal data on the Acino Website upon request, this Visitor has an unlimited right to access, edit, and revoke this data. In addition, the Visitor can prohibit Acino from contacting him or her. Visitors wishing to contact Acino in relation to the use of personal data are asked to e-mail Acino at dataprotection@acino.swiss. Acino will require the name of the website where the data has been registered, as well as detail of the specific data to be updated or revoked. Acino will treat such requests accurately and promptly. Requests to revoke Personal Data will be executed in accordance with all applicable legal and ethical requirements for documentation handling and archiving.

Rights related to consent:

1. A Data Subject will always be entitled to inform Acino about his or her wish to withdraw the consent for the Personal Data Processing.
2. You will be able to view, change and withdraw your consents given to Acino by contacting Acino at dataprotection@acino.swiss.

Data Subject also has the following rights, but in view of the obligation to maintain professional confidentiality, Acino assesses at all times whether and how the Data Subject’s rights are exercised. In general, the data subject has the following rights:

1. Right to receive information i.e. the right of a Data Subject to receive information regarding the Personal Data collected about him or her.
2. Right of access to data which, inter alia, includes the right of a Data Subject to a copy of the Processed Personal Data.
3. Right to rectification of inaccurate Personal Data. A Data Subject will be able to correct inaccurate data by contacting dataprotection@acino.swiss.
4. Right to erasure of data i.e. in certain cases a Data Subject will be entitled to demand the deletion of Personal Data, for example if the Processing is carried out only on the basis of a consent.
5. Right to demand restriction of Personal Data Processing. This right is created, inter alia, in case the Personal Data Processing is not permitted under law or if the Data Subject challenges the accuracy of the Personal Data. A Data Subject will be entitled to demand the restriction of the Personal Data Processing for a period enabling the processor to check the accuracy of the Personal Data or if the Personal Data Processing is unlawful but the Data Subject does not request the deletion of the Personal Data.
6. Right to data portability i.e. a Data Subject shall have, in certain cases, the right to receive the Personal Data in a machine-readable format, and to take this data along or transfer it to another controller.
7. Rights related to automated Processing mean, inter alia, that a Data Subject will have the right to object, on grounds relating to his or her particular situation, at any time to Processing of Personal Data concerning him or her, based on automated decision-making. For the avoidance of doubt – Acino may Process Personal Data for automated decision-making promoting its business (i.e. for segmentation of Visitors in marketing context, and for sending them personalized messages, in the context of commencement of an employment relationship, and in order to ensure that our employees shall adhere to our internal security regulations). Automated Processing may include also data collected from public sources. Acino does not create individual profiles for Data Subjects as a result of the use of the Website. You have the right to avoid any decisions based on automated Personal Data Processing if they can be classified as profiling;
8. Right to the assessment of a supervisory authority on whether the Processing of the Personal Data of the Data Subject is lawful;
9. Compensation for damage, if the personal data processing has caused damage to the data subject.

Acino may record anonymous data about visiting patterns on its Websites covering the pages visited or the searches performed. A visit may lead to information in the form of Cookies being stored on your computer. Acino uses session Cookies, persistent Cookies and advertising Cookies. A session Cookie is deleted automatically after every visit; persistent Cookies shall remain upon repeated use of the Website, and advertising Cookies and third party Cookies are used by the Websites of the partners of Acino which are connected with the Website of Acino. Acino does not control the generation of those Cookies, therefore information on these Cookies can be obtained from third persons.

The Cookies that Acino uses are following:

Third Party Cookies: We use Google Analytics to help us analyse the traffic on our Website if you have given your consent via Cookie banner. These cookies collect information about how Visitors use our Websites, including details of the site where the visitor has come from and if a visitor has been to our website before. The cookies do not identify visitors personally, instead they collect information in an aggregated form. Information collected through third-party plug-ins and widgets on the Website (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and Acino is not responsible for those providers’ information practices.

• Google Analytics: tools.google.com/dlpage/gaoptout

Necessary Cookies: We also use Cookies to enable core functionality such as security, network management, and accessibility. Visitors can disable these by changing their browser settings, but this may affect how the website functions.

Cookies do not harm computers. However, Visitors may prefer to configure their browsers to issue a permission request before any Cookie can be installed. Acino may use the services of third parties to collect and process the information described in this paragraph. Such third party services are subject to the same obligations as described in this Privacy Notice.

Acino ensures that no information is collected or embedded in tags or Cookies that could in any way identify individual Visitors by revealing a name, address, e-mail address or even telephone numbers for example.

Most of the web browsers allow Cookies. Without fully allowing Cookies, the functions of the Website are not available to a Visitor. The allowing or prohibiting Cookies and other similar technologies shall be under the control of a Visitor via the settings of the Visitor’s own web browser, settings of the information society service and platforms for making such privacy more efficient.

You can find more information about Cookies here:

1. All About Cookies (in English): Descriptions of Cookies and other web technologies;
2. Your Online Choices; About Ads; Network Advertising  (in English): the platform of controlling and monitoring of Cookies and other web technologies, where Data Subjects themselves can change and control how their Personal Data are used and collected.

Modify Your Consent Preferences:

To give your consent to the processing of data by Acino and the transfer of data to third parties, or to tailor your consent for specific data processing purposes, please click here.

The Services of Acino, including the information society services, are not targeting children.

Acino does not knowingly collect any information on persons under 13 to 16 years of age and in case of any respective informed activity we shall act on the basis of the requests of a parent or guardian.

Acino will disclose all details to the legal representative of the child. The representative will have the right and the opportunity to update and revoke the Personal Data of the child at any time. Acino complies with the legal requirement to protect children.

In case Acino finds out that it has still collected Personal Data from a child or regarding a child, Acino shall use its best efforts to discontinue the Processing of the respective Personal Data.

The present Privacy Notice is only applicable to Acino Websites and explicitly excludes third party websites. Acino may link to third party websites of interest and relevance to Visitors at its discretion. Acino strives to ensure that linked pages and sites meet the highest standards. Due to the rapidly changing nature of the Internet, Acino cannot take responsibility for the privacy provisions and the content of linked websites. To repeat, this Privacy Notice does not cover linked websites.

You may have a question or even a complaint regarding the Personal Data protection, collection or processing on Acino Websites. Or you may have concerns about compliance with legal principles. For any of these concerns related to Personal Data, or if you would simply like to offer comments or suggestions about the Acino Personal Data Notice, please contact Acino International AG as follows:

Acino International AG
Thurgauerstrasse 36/38
CH-8050 Zurich
E-mail dataprotection@acino.swiss

Acino will be entitled to unilaterally amend this Privacy Notice.

Last updated December 2022