Merck Serono Limited in the UK and/or Merck Serono (Ireland) Limited in Ireland as the case may be (“Merck”, “we”, “us” or “our”) and any other Merck affiliates respect the privacy of visitors to our websites and are committed to the protection of their personal information.
This policy together with our website’s Terms of Use, (and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us and for which purposes.
The MySupport patient support program is set up by Merck and delivered to you by Lloyds Clinical Pharmacy Homecare (LPCH) for patients in the UK and by Temperature Controlled Pharmaceuticals Ltd (TCP) for patients in the Republic of Ireland (“Patient Support Program Provider”). Merck and the Patient Support Program Provider are joint controllers in relation to the set up and delivery of the MySupport patient support program. However the Patient Support Program Provider is not responsible for this website.
This privacy policy only governs the processing of data on the MySupport website for which Merck is the sole data controller.
Please note that this website is for use and access only by patients who have been prescribed Saizen® (Somatropin) and who have been provided registration details to the website. Patients can also be referred to as “you”.
1. Which data is collected and used?
In the course of the website, Merck is collecting and using the following data:
- Topics a user is interested in to recommend content
Important: Even though the MySupport is set up by Merck, Merck will not have access to the names of any single user and will not identify such users (except in legally required cases like drug safety adverse event and reporting). Merck will only receive de-identified information without a name as further described below.
Merck will also collect browsing data, which Merck will not connect to individual users. This includes the name of the internet service provider, the website from which you access our website, the websites you looked at, temporarily your full IP address and the date and duration of your visit.1
2. For which purposes will your data be used, where will it be stored and how will it be protected?Use of data for IT services
a) Use of data for IT services
All data will be stored in a centralised database located in the European Union and operated by the technical services provider AWS. The technical services provider may access data for the maintenance, operation or administration of the website and the database.
That access may also take place from outside the European Union; Merck will take all steps reasonably necessary to ensure that the data you provide is adequately protected at all times (including in the event data is transferred outside the EU/EEA) according to the requirements of the data protection laws of the UK, Ireland and the European Union, by means of Standard Contractual Clauses approved by the EU Commission.
Protection of your identity: When data is accessed for IT administration services, your identity will always be protected. Data sets are identified by a code number, not by your name so the technical service provider is not aware of your identity when providing the IT services. Access to the full data (including name) for IT services will only be required in exceptional cases (e.g. in case of a severe software problem).2
b) Statistical reports
To understand the use and to improve our patient support programs, Merck will receive aggregated statistical reports, business reviews, which are used to help understand user behavior and improve MySupport or similar programs. Such reports will never contain data about single patients and are never used to support a decision about a single patient.3
c) Adverse events and protection of rights
The Patient Support Program Provider may share personal information (including name) with Merck in case of a suspected adverse reaction to your treatment, or a product related issue. Merck companies are required by law to document and share the relevant information, including personal information with authorities worldwide (such as the MHRA in the UK, HPRA in Ireland and the European Medicines Agency (EMA))4 and, where necessary for further assessment, to contact the persons who report this information.
In order to enforce or to protect our rights, and where appropriate third parties‘ rights, Merck can share your data with the holders of such rights and authorities in order to enforce or to protect our rights or the rights of third parties.
d) Surveys
In addition, from time to time, the Patient Support Program Provider may contact you to ask you if you would like to participate in any survey or market research into medical conditions, or into the usefulness of the information and service that Merck provides. However you are under no obligation to participate and if you agree to participate, an independent professional service provider will conduct such survey or market research on our behalf in order to preserve the anonymity of respondents and to ensure that the research is unbiased.5
e) General statistics, website security:
Merck uses browsing data of users for creating aggregated statistics (so that statistics do not show data about a single user but only about the collective data of a number of users), to learn what is of interest to users in order to improve websites and services. This includes date and time of access, operating system, type of device, quantity of data transmitted, server requests and temporarily your full IP address. Merck will also use the browsing data for maintaining or restoring the security of the website as well as to detect and correct technical defects and errors.6
Merck also collects data about the location of the devices accessing our website for statistical purposes (statistics from where visitors access our website, etc.); you can control the authorisation for this using the browser settings.7
3. Cookies and Analytics
a) Cookies
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.
We use the following categories of cookies on our website:
| Cookie Category | Description |
| Necessary | These cookies are necessary for the website to operate. Our website cannot function without these cookies and they can only be disabled by changing your browser preferences. |
| Statistics | In order to continuously improve our website, we anonymously track data for statistical and analytical purposes. With these cookies, we can, for example, track the number of visits or the impact of specific pages of our web presence and therefore optimise our content. |
| Comfort | These cookies allow us to provide more comfort for you. For example, previously searched products or services can be reloaded again after revisiting our website and you won’t need to enter all the details again. We can also detect if you need assistance with using our website and therefore offer you direct customer support. |
| Personalisation | These cookies are used to display personalised content matching your interests. We can display personalised and relevant services to ensure that you are always up to date on related offers. |
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website. To find out more about cookies, including to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
b) Google Analytics
This website uses Google Analytics, a web analysis service provided by Google Inc. (“Google”) to store “analytical cookies” on your device.8 This means that information about users and the use of our website is transmitted to Google and processed on our behalf for the purpose of compiling reports on website activity, measuring website visits and visitors and providing similar services for us. This includes the transmission of your IP address, but it will not be merged with other Google data. In addition, your IP address is shortened (usually within the European Union) and saved by Google only in an abridged form. For data storage in the United States, Google has entered into EEA-Standard Contractual Clauses between its relevant entities to cover these transfers.
You can object to the processing of your data for these purposes by installing a browser plugin (https://tools.google.com/dlpage/gaoptout?hl=en-GB).
c) Adobe Analytics
This website uses Adobe Analytics, a web analytics service provided by Adobe Systems Software Ireland Limited (“Adobe”) to store “analytical cookies” on your device.9 This means that information about users and the use of our website is transmitted to Adobe and processed by us on our behalf for the purpose of compiling reports on website activity, measuring website visits and visitors and providing similar services to us. This includes the transmission of your IP address, but will not be merged with other Adobe data. In addition, it is pseudonymized prior to the geolocalization and replaced by a generic IP address before storage. As data can be transferred to the USA in exceptional cases, Adobe has entered into EEA-Standard Contractual Clauses between its relevant entities to cover these transfers.
You can object to the processing of your data for statistical purposes by using the following link (“Use of Adobe Marketing Cloud by our business customers” section): https://www.adobe.com/uk/privacy/opt-out.html.
4. Data Retention
Data which is collected while browsing our website and which can legally be considered personal data (such as the complete IP address) is stored for a period of time of no longer than 14 days, unless a reasonably justified incident indicates a longer storage period (e.g. due to a hacking attack).
Data without any personal identifiable information may be stored permanently.
5. Data protection rights and contact
a) General rights
You have the right to request a copy of the data that we hold about you. You also have the right to ask us and/or the Patient Support Program Provider (i) to correct the data we hold about you if you believe it incomplete or inaccurate; or (ii) to delete or remove personal data we hold about you; or (iii) to limit our processing where you believe there is no good reason for us continuing processing it.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
b) Right to object
You can also object to the processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. This applies in particular to the collection of your data for statistical measurement of the web audience by Google Analytics and/or Adobe Analytics.
c) Revocation of your consent
You may withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. This will not affect the treatment you receive from your doctors/clinics or the previous use of your data.
d) Contact
We are committed to ensure the protection of your personal data. If you have any queries in relation to this privacy and cookie policy, including any request to exercise your legal rights, please contact Merck’s Medical Information Department using any of the following contact details.
In the UK contact:
Merck Serono Limited
5 New Square
Bedfont Lakes Business Park
Feltham, Middlesex TW14 8HA
Tel: 020 8818 7373
Email: UKIenquiries@merckgroup.com
In Ireland contact:
Merck Serono (Ireland) Limited
4050 Kingswood Road,
Citywest Business Campus
Dublin 24, Ireland
Tel: 1800 719881
Email: UKIenquiries@merckgroup.com
For queries related to the MySupport patient support program, please contact the relevant Patient Support Program Provider (LPCH or TCP) using the following details:
In the UK contact:
Freephone: 0800 783 4660
Email: lpch.mysupport@nhs.net
In the Republic of Ireland contact:
Freephone: 1800 409 217
Email: mysupport@tcp.ie
In addition you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) or to the Office of the Data Protection Commissioner, the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the relevant competent authority, so please contact us in the first instance.
Data protection declaration as of: August 2022
Document Number Template: UI-MULCMC-00002 Sept 22
- Legal basis: Art. 6 (1) f) GDPR.
- Legal basis: Art. 9 (2) a) GDPR.
- Legal basis: Art. 9 (2) a) and Art. 89 GDPR.
- Legal basis: Art. 9 (2) b) GDPR.
- Legal basis: Art. 9 (2) a) GDPR.
- Legal basis: Art. 6 (1) f) GDPR.
- Legal basis: Art. 6 (1) f) GDPR
- Legal basis is Art. 6 (1) f) GDPR.
- Legal basis: Art. 6 (1) f) GDPR.