Allergan Privacy Notice MEA Region: Middle EastEffective Date: 1st April 2021
This Privacy Notice explains how Allergan Middle East Ltd., Unit 802 Level 8 Index Tower, Dubai International Financial Centre, P O Box 506964, Dubai, United Arab Emirates (referred to as “Allergan,” “we,” “our,” or “us”) may process Personal Data about you through your online and off-line interactions with us through Allergan services, products, communications, and digital properties (including websites and mobile applications) that refer to this Privacy Notice and where Allergan may obtain and control your Personal Data from a third party (collectively, “Allergan Relationships”).
Your Personal Data We May Collect
This section describes the general categories of Personal Data that we may collect for the purposes described in this Privacy Notice.
Personal Data we collect from you or from other sources
Allergan may collect Personal Data from you directly, for example as part of a registration or in response to a questionnaire. Allergan may also obtain Personal Data indirectly, such as from publicly available sources (e.g., websites or publicly accessible databases), third-party data vendors, health care providers and health insurance companies, and third-party partners and collaborators. We may combine Personal Data from multiple online and off-line sources. The categories of Personal Data that Allergan may collect about you include:
- Direct identifiers and contact information, including your name, address, phone number, or email address
- Registration information, such as your username and password
- Relationship data, including information about products, treatments and health conditions that are of interest to you
- Transaction data, including purchases and inquiries
- Financial account data, such as your credit card number
- Income and demographic information, such as when you request financial assistance for one of our products
- Health-related information, such as information about a health condition, safety and health information in relation to any of our products, or insurance and demographic information
- Payment-related information if you provide a service to Allergan
How we may use Personal Data
We may use your Personal Data for the business and commercial purposes relating to your Allergan Relationships, communicating with you, improving Allergan Relationships and our products and services, and for other internal business purposes. .
Administering programs, services, and other interactions with you
We may use your Personal Data for everyday business purposes, such as payment processing and financial account management, contract management, website administration, fulfilment, corporate governance, and reporting obligations. We may also use your Personal Data to provide you with the programs or services that you requested, or to administer Allergan services, such as direct purchasing, participating in a savings program or signing up to receive a rebate. This means that we may use your Personal Data to respond to your questions, provide you with your requested services, offer you an optimal customer experience, perform our contractual obligations to you, or perform actions based on your consent.
Marketing communications and disease awareness
We provide marketing communications that promote the use of or offer participation in Allergan products, services, programs, research events or provide other information that may be of interest to you, such as information on certain health conditions. We will use your Personal Data to send you marketing communications and to determine the types of marketing communications to send.
You can opt-out of marketing communications at any time. Marketing communication opt-out instructions are included in each marketing communication you receive, or you can email us at email@example.com.
Customized experiences and improving relationships
Personal Data may be used to create customized offers, information, or services tailored to your interests and preferences. It may also be used to develop and improve your Allergan Relationships. In some cases, we collect your Personal Data with your consent. In other cases, we collect this information for our legitimate business interest to optimize and customize Allergan Relationships.
Business and product administration and improvement
In order to discover new facts that could help Allergan better understand customer needs and help improve, develop, and evaluate product services, materials, programs, and treatments, Allergan analyzes Personal Data for its legitimate interests in business and product improvement.
Compliance with laws and regulations
We may process your Personal Data to comply with laws and regulations, including those related to pharmacovigilance. We may also use Personal Data to monitor compliance with our policies and procedures, for fraud prevention, and to investigate and prosecute users who violate our rules or who engage in behavior that is illegal or harmful to others or to others’ property.
How we may disclose Personal Data
We generally share Personal Data with third parties for the business and commercial purposes described below. We do not sell Personal Data to third parties.
Affiliates and vendors
We have relationships with various vendors, including our affiliated companies, that help us operate our business and for whom it may be required to have access to your Personal Data in the course of providing services to Allergan. We require them to handle your Personal Data collected through the Allergan Relationships in accordance with appropriate contractual privacy and security provisions.
Business and research partners
We may partner with other companies and public and private organizations to provide you with products, content, or services on a joint or “co-branded” basis. You should be aware that, in such cases, in addition to this Privacy Notice, the relevant partner’s privacy notice may also apply, and, in limited cases, there may be a shared privacy notice.
For co-branded forms and sites, you will see displayed both the Allergan logo and the logo of the co-branding partner. To access co-branded services, you may have to complete a registration form, and this registration information may be shared with Allergan’s co-branding partners, and you should read the individual privacy policies of our co-branding partners, as they may differ in some respects from ours.
In addition, we may disclose Personal Data to our external auditors, attorneys, accountants, and similar professionals based on our legitimate interest in the operation of our business and our obligations to comply with applicable laws and regulations.
Disclosures for legal obligations, to authorities and for product safety
If you contact Allergan regarding your experience using our products, we may use the information you provide to us to submit our reports to the U.S. Food and Drug Administration, other similar health and medicine government agencies across the world, and as otherwise required of us by law. We also may use the information to contact your prescribing physician to follow up regarding an unexpected event involving the use of our product.
In certain limited circumstances, we may need to disclose your Personal Data to comply with a legal obligation, process, or demand and for reasons of public interest, such as to comply with reporting obligations to our governing regulatory authorities regarding the safety of our products, in response to a subpoena, or to meet national security or law enforcement requirements.
Disclosure to subsequent owner or operator
We may transfer your Personal Data to a successor entity upon a merger, consolidation or other corporate reorganization, to a purchaser of all or a portion of our assets, or pursuant to a financing arrangement or co- promotional agreement. The Personal Data we have about you may be transferred to parties to the transaction based on our legitimate interest in preparing for and completing the transaction. Any successor entity shall be bound by terms and conditions reasonably similar to this Privacy Notice.
Additional information for online interactions and cookies privacy statement
We may collect additional categories of Personal Data relating to your online interactions with us, as described in this section. We also use, share, and disclose your Personal Data for online interactions for the additional purposes described in the section. The categories of Personal Data collected and the purposes of use and disclosure described in this section are in addition any other collection, use and disclosure of Personal Data practices described separately in this Privacy Notice.
Personal Data that may be collected automatically through our websites and mobile applications
We may collect the following additional categories of Personal Data through your usage of our websites and mobile applications.
We may record the Internet Protocol (“IP”) address of your computer or other electronic device when you visit our website. An IP address identifies the electronic device you use to access websites, which allows us to maintain communication with your device and to customize content.
Cookies and other data-collection technologies
We collect information automatically through your online interactions with us through tracking and data-collection technologies such as cookies, web beacons and pixels, APIs, web services, scripts, browser analysis tools, and server logs. A “cookie” is a unique numeric code that is transferred to your computer to track your interests and preferences and to recognize you as a return visitor. A “Web beacon” (also known as a pixel tag) is a transparent graphic image placed on a website, email, or advertisement that enables the monitoring of things such as user activity and site traffic, including the collection of data about the website and mobile application you were visiting before and after you came to our website or mobile application. To learn more about cookies and other data-collection technologies, please visit all about cookies.
We classify our cookies into the following categories:
- Required Cookies: These cookies are necessary for core features of a site to operate
- Functional Cookies: These cookies allow us to analyze site usage to evaluate and improve its performance. They are also used to provide a better user experience on the site, such as measuring interactions with particular content or remembering
- Advertising Cookies: These cookies are used to show you ads that are more relevant to We may share this be used to share data with advertisers so that the ads you see are more relevant to you, allow you to share certain pages with social networks, or allow you to post comments on our site.
If you would like to see a detailed list of the cookies we use on our websites, including the third parties that place cookies on our websites, the specific cookie, and cookie lifespan, please click on “cookie settings.” If the cookie lifespan is not disclosed in the cookie settings, we use a default life span of thirteen (13) months, unless a shorter period is required by law. You can also use the “cookie settings” to opt out of a nonrequired cookie category.
In addition to the cookie settings feature, you can disable cookies through your browser. Please note that some cookies are essential to the functioning of our websites and deleting or disabling them on your browser will reduce the site’s functionality.
If you want to use your browser instead of our cookie settings feature to opt-out of the Google Analytics or Adobe Analytics tracking cookies, you can install the Google Analytics opt-out browser add-on, and you can opt-out of Adobe Analytics.
Some Allergan Relationships are available as either mobile applications or mobile sites that you can use on your mobile device. If you use a mobile device to access and use the Allergan Relationships, we may collect the following mobile- specific information in addition to the other information described above: device or advertising ID, device type, hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), the version of your mobile operating system, the platform used to access or download the Allergan sites and applications (e.g., Apple, Google, Amazon, Windows), location information and usage information about your device and your use of the Allergan Relationships.
How we may use Personal Data through online interactions
In addition to the uses described separately in this Privacy Notice, we may use your Personal Data collected online for the additional purposes as described in this section.
Customized user experiences
In some cases, we collect this Personal Data with your consent. In other cases, we collect this information for our legitimate business interest to optimize and customize your user experience.
Digital analytics and improvement
We may use the Personal Data that you provide to us and the online information we collect automatically through cookies and similar tracking technologies to monitor user traffic patterns and preferences. We may also track email communications through web beacons or similar tracking technology in emails to create aggregated statistics and reports to analyze the effectiveness of and improve our marketing campaigns.
We collect this information for our legitimate business interests of security, improvement, analytics and optimization of Allergan Relationships
Social Media Analysis
We may offer “tell-a-friend” functionality on our sites. If you choose to use this function, we will collect your friend’s contact information. We will automatically send your friend a one-time email with the information you specified or inviting your friend to visit the site. We use this Personal Data you provide us as part of the “tell-a-friend” functionality for the sole purposes of sending this one-time email.
How your Personal Data may be shared through online interactions
In addition to the types of disclosures of Personal Data described separately in this Privacy Notice, we may share Personal Data online for the additional purposes as described in this section.
Third-party advertising and online behavioral advertising
We may provide you with online advertisements for Allergan products and services on third-party websites and mobile services that are tailored to you, which may be based on the Personal Data that you provide to us or to a third-party website that you are visiting, or on your browsing activity, purchases, or interests. We may share some of your device information with our advertising service providers that we have obtained from cookies and other data-collection and tracking technologies based on your Allergan Relationships.
You may also opt out of certain online behavioral advertising on the Digital Advertising Alliance's consumer choice tool, and the Network Advertising Initiative’s tool.
Some web browsers may transmit “do-not-track” signals to web services with which your browser communicates. As of the effective date of this Privacy Notice, an industry standard has not yet been established on how to respond to these signals; therefore, Allergan does not currently respond to these signals. However, you can opt-out from advertisers that use your browsing history to deliver online behavioral advertisements via the mechanisms listed above.
Links to third-party sites and social media plug-ins
This Privacy Notice only applies to Allergan Relationships linked to this Privacy Notice and does not apply to third- party websites to which Allergan Relationships may link, including links to outside websites or advertisements from third parties. We encourage you to review the privacy statements provided by all third parties prior to providing them with Personal Data.
Allergan Relationships may use social media plug-ins (e.g., the Facebook “Like” button and the “Share to Twitter” button) to enable you to easily share information with others. When you visit our sites as part of an Allergan Relationship, the operator of the social plug-in and integrated social media platforms can place a cookie on your device that enables that operator to receive your Personal Data that allow the operator to recognize individuals who have previously visited our sites. If you are logged into the social media site (e.g., Facebook, Twitter) while browsing on our site, the social media plug-in allows that social media site to receive information that you have visited our site. The social media plug-in also allows the social media site to share information about your activities on our site with other users of that social media site. These sharing settings are managed by the social media site, and you should refer to those sites’ privacy policies for information about their privacy and data-sharing practices.
Additional information for job applicants
If you have applied for employment with Allergan, the Personal Data submitted with your job application may include your resume; previous professional, education and other background information; driver’s license information; social security number or equivalent national identification (as required or permitted by local law); cover letter; licenses; permits and certifications held; reference information; and any other information that you choose to provide (e.g., employment preferences, willingness to relocate, awards or professional memberships). This information may come from you, a recruiter, your references, prior employers, or your educational institutions.
Consistent with applicable law, we may ask questions about race/ethnic origin, gender, veteran status, and disability status of our applicants, for the monitoring of equal employment opportunity compliance. Except as specifically requested or legally required, we ask that you avoid submitting information in your application that may qualify as sensitive information under applicable law. Sensitive information includes data about race, color, religion, ethnicity,
nationality or national origin, age, gender identity or expression, sexual orientation, marital status, medical or health information (including physical or mental disabilities or pregnancy status), genetic or biometric information, political or philosophical beliefs, political party or trade union membership, veteran status, photographs, background check information, judicial data such as criminal records or information on other judicial or administrative proceedings, or any other legally protected status.
Personal Data will be processed based on our legitimate interest in processing your job application and evaluating your candidacy and qualifications and to conduct reference checks. We may also inquire about criminal records and perform a background check following a conditional offer of employment, where permitted by applicable law. We may also process Personal Data from your job application for regulatory, compliance and legal purposes, consistent with this Privacy Notice. Personal Data may be also be used for additional administrative purposes, including aggregate management reporting, internal training, and as generally required to operate our business.
We may share the data on your applications with recruiters, consultants, attorneys, preemployment background check services, and our affiliates.
Additional information for health care professionals
We may collect additional categories of Personal Data if you are a health care professional, as described in this section. We also use and disclose Personal Data about health care professionals for the additional purposes described in this section. The categories of Personal Data collected and the purposes of use and disclosure described in this section are in addition any other collection, use and disclosure of Personal Data practices described separately in this Privacy Notice.
Additional Personal Data that Allergan may collect about health care professionals
If you are health care professional, we may collect Personal Data about you directly from you, or from third-party sources such as the organization where you work, publicly available sources, interactions with Allergan (including online available sources), and participation in Allergan-sponsored or -supported initiatives such as Allergan-sponsored clinical research and development activities, third-party databases, and reporters of pharmacovigilance events.
We may collect the following additional categories of Personal Data about health care professionals:
- Professional details, such as resumes or other documents or forms provided directly to us, place of practice, job title, professional contact details, medical specialty, professional license number, professional qualifications and scientific activities (such as previous clinical trial experience, activity on social media platforms or other websites, and participation in past or pending research studies with us and other companies), organizational or institutional affiliations, publication of academic or scientific research and articles, and membership in associations and boards
- Personal Data provided to participate in our sponsored or -supported initiatives, such as our sponsored clinical research and development activities, online or in-person seminars regarding product information, educational events, and clinical information updates
- Details of interactions with us, such as what kind of meetings we have held, topics discussed, your knowledge of and questions you have had about our business and products, what kind of material we have displayed to you, and any feedback that you have provided, as well as your opinions of and routines for prescribing, routines regarding your patients, diagnoses, and automatic tracking information in online interactions with us
- Payment and other transfers of value details received from your interactions with Allergan, which may include your tax identification number or national identification number (where required or permitted by law), contributions to costs of educational events (such as registrations fees, travel and accommodation expenses) and fees for services, including consultancy services
Additional uses and disclosures of health care professional Personal Data
We use and disclose Personal Data of health care professionals for the following additional purposes.
- For the performance of our contract with you if you or your institution entered into a consulting, professional services, or other type of agreement with
- Based on our legitimate interests in developing and improving our services, we will use and disclose Personal Data about health care professionals for:
- managing and improving our relationship with you, including planning, organizing and reviewing any collaboration with you, and for contacting you
- helping ensure that we provide you with information that is relevant based on your expertise, interests and preferences
- recruitment and evaluation of the suitability of health professionals for their participation in clinical trials and market research and other research studies
- conducting market and research studies in the public and private sectors
- communicating with you about our products and programs (subject to any additional marketing consent requirements), engage with you about scientific or educational programs, administer our patient-support programs and provide access to you where applicable, respond to product orders, and provide product samples
- research and analytics purposes to develop and evaluate our products, services, materials and treatment
- internal accounting and analysis in connection with our internal policies and rules, such as our Allergan Code of Business Conduct
- Based on our legal obligations and for reasons of public interest, we will use and disclose Personal Data about health care professionals for:
- safety monitoring, reporting and auditing and responding to inquiries or issues in relation to our products
- complying with applicable laws and regulations, including requirements imposed by industry codes of conduct to collect payment and other transfer of value data of health care professionals and the public disclosure of such data, subject to applicable local consent requirements to publish such data in a manner that identifies the health care professional individually
Additional information for participants in patient and customer programs
We may collect additional categories of Personal Data about participants in Allergan’s patient and customer programs, as described in this section, including patient support programs and loyalty programs. We may also use and disclose Personal Data about participants in patient and customer programs for the additional purposes described in this section. The categories of Personal Data collected and the purposes of use and disclosure described in this section are in addition any other collection, use and disclosure of Personal Data practices described separately in this Privacy Notice.
Additional Personal Data that Allergan collects for Patient and Customer Programs
If you are a participant in a patient or customer program, we may process the following additional categories of Personal Data about you, which we received from you directly, or from your health care professionals, health care insurers, and related third parties:
- contact data such as address, phone number and other contact details
- personal details such as name, date of birth and gender
- data collected or created regarding your use of our programs and services
- financial information related to qualification in certain income-based and financial support programs, including your social security number or national identification number (where permitted or required by law)
- sensitive data such as health data relating to your disease or condition, medical history, treatment, reason for discontinuation, data on active management of the disease and insurance coverage and benefits related to your use of our products
Additional uses of data in the context of patient and customer programs
With your consent, we use and disclose your Personal Data as part of your program participation to administer and manage the program, including customization of the program to you, delivery of products and services, administering loyalty programs, reminding you to take your product as prescribed or to obtain a refill of your product, and to provide you with program support, communications, and materials relating to your treatment and the program. We may also contact your health care professional for drug safety information and to provide health care professional with information about your medicine and your participation in a program.
Based on our legal obligations and for reasons of public interest, we may use and disclose your Personal Data in our programs for safety monitoring, reporting and auditing, and responding to inquiries or issues in relation to our products, as well as to comply with applicable laws and regulations.
We will also use Personal Data that does not directly identify you for the compatible purposes of analytics, research and related publications, including to evaluate, develop and improve Allergan's programs and related services, products and medicines.
Privacy of children
Allergan does not knowingly collect any Personal Data directly from anyone under the age of 13. All Allergan Relationships that support children are directed to and are communicated with parents and guardians only. If you are a parent or guardian and become aware that your child has provided us with Personal Data, please contact us using one of the methods in the Your privacy rights and choices section, and we will work with you to address this issue.
Our contact information
You may contact us or our Global Privacy Office, including our Data Protection Officer, at any time, using the contact information below if you have questions about this Privacy Notice or have any other privacy request or inquiry. You can also opt-out or unsubscribe from any of our programs or services.
Please submit your privacy requests or inquiries via https://www.abbvie.com/privacy-inquiry.html Contact us by emailing us at firstname.lastname@example.org, or by sending a letter to the following address:
Attention: Global Privacy Office 2525 Dupont Drive
Irvine, CA 92612 USA
In all communications to us, please include the email address used for registration (if applicable), the website address, mobile application, or the specific program to which you provided Personal Data (e.g., Allergan.com), and a detailed explanation of your request. If you would like to delete, amend, or correct your Personal Data and are contacting us by email, please put “Deletion Request” or “Amendment/Correction Request” in the subject line of the email. We will respond to all reasonable requests in a timely manner, and we may need to further confirm your identity in order to process certain requests.
Your privacy rights and choices
Under applicable data protection law, you may have the right to request access to and/or rectify, block, or delete Personal Data relating to you, transmit Personal Data to another controller, withdraw your consent at any time (this will not affect the lawfulness of previous data-processing activities), or object to any use of your Personal Data. If we are not able to provide the requested information or make the change you request, you will be provided with reasons for such decisions. Under local law, you may be entitled to lodge a complaint with your local data-protection authority.
You may have the right to object to the processing activities described in this Privacy Notice that are based on our legitimate interests.
Please submit your privacy requests or inquiries via https://www.abbvie.com/privacy-inquiry.html or by email at email@example.com
Data security and retention
Allergan maintains appropriate technical, administrative, and physical controls to reasonably safeguard any Personal Data collected through Allergan Relationships. However, there is always some risk that an unauthorized third party could intercept an Internet transmission, or that someone will find a way to thwart our security systems. We urge you to exercise caution when transmitting Personal Data over the Internet, especially your health-related information. We cannot guarantee that unauthorized third parties will not gain access to Personal Data about you; therefore, when submitting Personal Data to us, you must weigh both the benefits and the risks.
We will only keep Personal Data as long as necessary for the fulfillment of the purposes outlined in this Privacy Notice, except if otherwise required by applicable laws or legal orders. The criteria used to determine our retention periods include (i) the length of time we have an ongoing Allergan Relationship with you; (ii) whether there is a legal or best practice retention obligation to which we are subject; and (iii) whether retention is needed in light of litigation or regulatory investigations.
International Personal Data transfers
We may transfer Personal Data internationally as described in this section.
Personal Data may be transferred and processed by and among Allergan Inc. in the U.S., the parent company of Allergan, and its affiliates in other countries. For a full list of Allergan Inc.’s affiliates and their jurisdictions, please see https://www.allergan.com/home. A. Our company maintains several inter-company data transfer agreements, which are based on EU model contracts for Personal Data transfers and covers Personal Data transfers among Allergan Inc. and its affiliates worldwide to ensure the adequate protection of Personal Data. Copies of these agreements can be obtained by sending an email to firstname.lastname@example.org.
Transfers to vendors, suppliers, and business partners
Personal Data may also be transferred and processed by our vendors, suppliers, and business partners in other countries. Any international transfer of Personal Data to third parties, including outside the EEA, will be conducted in compliance with the international data-transfer restrictions and requirements that apply under data-protection laws, including, where appropriate, using EU model contracts for Personal Data transfers to data processors or data controllers.
Accessing our sites globally
This site is owned and operated by Allergan in the United States. If you are visiting this site from a country other than the United States, your communication with us will result in the transfer of Personal Data across international borders. We will only process your Personal Data with your consent, to perform a contract between you and us, to comply with legal obligations, or where we have a legitimate interest. These legitimate interests include administrative activities and complying with your requests.
Changes to our Privacy Notice
We will use Personal Data only in the manner described in the Privacy Notice in effect when the Personal Data was collected. However, and subject to any applicable consent requirements, we reserve the right to change the terms of this Privacy Notice at any time. Any changes to this Privacy Notice will be promptly posted to this page and accompanied by a new effective date at the top of this page. We encourage you to review this Privacy Notice regularly for any changes. Any Personal Data collected upon your continued use of Allergan Relationships will be handled in accordance with the currently posted Privacy Notice.