Privacy Notice for Health Care Professionals & Employees or Representatives of Healthcare Organizations

argenx and its affiliates (“argenx” or “we”), each a Data Controller, is committed to protecting your privacy and will make all reasonable efforts to protect your personal data (“Personal Data”) in accordance with applicable data protection laws, including but not limited to the General Data Protection Regulation 2016/679 (“GDPR”), the UK and Swiss Data Protection Acts as amended and in force and this Privacy Notice (“Notice”). You can find more information on argenx affiliates in Europe and worldwide and their contact details here: https://www.argenx.com/contact-us  

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

• personal details, such as name, age, gender, nationality; government issued licenses or documents (e.g. passport information and/or tax identification information);
• business contact information, such as your business postal address, telephone, mobile and fax number, e-mail address;
• financial details, such as banking information (for the purpose of making payment to you pursuant to a valid contractual relationship);
• professional details such as employer, licenses, your place of medical practice, job title, educational history, your CV, the medical field in which you are active, professional qualifications and scientific activities (such as previous clinical study experience, and participation in past or pending research studies with argenx and other companies), employment status, publication of academic or scientific research and articles, memberships in associations and boards, speaking engagements, travel and expense information;
• details of interactions with us and your interests, such as type of meetings we have held, your attendance to events/congresses, topics discussed, your knowledge of and questions you have had on our clinical study activities and products, your interest in argenx products and your general prescription habits and any other information you may provide to us in our interactions.
• social media content and related social media online activity that is made publicly available by you.

We will usually collect this information directly from you, as well as from publicly available sources such as professional directories (e.g., Medical Societies, Medical Associations), social professional networks (LinkedIn, Twitter), online scientific publications, (e.g., Medical Journals) or professional subscription dataset/databank owned by third-party service providers (such as Veeva, IQVIA).

argenx will collect and process your Personal Data for one or more of the following purposes to:

• contact you to arrange face to face or remote meetings;
• enter into or renew a contract to which you are a party and administer our customer relationship;
• publicly disclose any transfers of value made to you, as a healthcare professional (HCP), as required by law or in order to comply with applicable industry standards; further information on our privacy practices in the context of transparency disclosure is available on our corporate website on our Transparency & Disclosure section.
• provide you with corporate news and updates on argenx;
• carry out promotional activities directed at you, subject to other applicable regulatory provisions;
• arrange (e.g., payment for travel & accommodation) your attendance or invite you to speak at scientific meetings, ad boards, congresses, and events organized by argenx;
• review a grant, donation, or sponsorship request that you may have applied for – whether or not - on behalf of your employer/institution, and assess your professional history for our due diligence purposes (including the HCP’s compliance with anti-bribery and corruption laws) and to determine the eligibility to receive the requested grant, donation, or sponsorship;
• provide to you, on your request, medical and scientific information as well as information & materials relating to our medicinal products and services; further information on our privacy practices in the context of handling medical enquiries can be found on our dedicated Medical Information, Adverse Events and Quality Complaints privacy notice.
• collect and report to regulatory authorities any adverse events reports or quality complaints; further information on our privacy practices in the context of handling medical enquiries can be found on our dedicated Medical Information, Adverse Events and Quality Complaints privacy notice.
• invite you to attend scientific events, e.g., webinars;
• provide you with information related to argenx clinical trials and invite you to participate thereto; Further information on argenx privacy practices in the context of clinical research can be found within our Sponsor Privacy Notice.
• invite you to share with argenx your professional insights, to participate in online or phone surveys and other market research activities; or
• collect and analyze your interests, professional insights, and activities to build or improve your professional profile as an HCP to develop, maintain, and further enhance our existing or potential professional relationship with you and to provide you with personalized information.

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

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

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

argenx may disclose your Personal Data to the extent legally required or permitted for the purposes mentioned above to the following categories of recipients which are bound contractually to comply with applicable data protection laws and regulations and argenx’s policies and procedures as applicable:

• argenx's affiliates for purposes related to our centralized business operations;
• selected third - party suppliers, vendors (acting as data processors) that provide supporting services to argenx related to argenx's business operations and to the purposes specified above (e.g. an event management company) as well as to our business partners (e.g. market research and fieldwork agencies, travel booking and accommodation agencies); and
• regulatory authorities, public/governmental and supervisory bodies, having the power to execute checks and investigations towards argenx in fulfilment of legal obligations or regulations.

Some of argenx’s affiliates and/or third – party service providers, acting for and on behalf of argenx and its affiliates as data processors, may be located in countries, where the  data protection laws may not have the same level of data protection than those laws in your country of residence or place of work (“Third Countries”),  including to the United States. For those cases where your Personal Data are being transferred to such countries, argenx has implemented adequate safeguards to protect your Personal Data. In addition, argenx relies on the execution of the EU Commission approved Standard Contractual Clauses for the transfer of Personal  Data outside of the EU/EEA, the UK and/or Switzerland and the implementation of appropriate technical and   organizational security measures to ensure the security of the processing. In adopting the appropriate safeguards, and/or any supplementary measures as may be required by applicable laws or supervisory authorities, argenx shall ensure that an adequate or essentially equivalent level of data protection is afforded by the importing entity to the data being transferred, taking into account the factual circumstances  of the transfer in question.

A full list of argenx data processors and additional information regarding the cross-border safeguards argenx has in place, is available upon request to our Privacy Office by email at privacy@argenx.com.

Your data will be securely stored in information assets owned by or managed on behalf of argenx by third party service providers (such as databank/dataset and IT providers) and may be hosted in Third Countries as noted above. Where this is the case, we take all necessary steps to ensure that adequate physical, administrative and technical safeguards are put in place to protect your Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction.

We retain your personal data for as long permitted by applicable laws and regulations and/or as deemed strictly necessary to achieve the intended purposes for which it has been collected. This time period may be extended for the establishment, exercise or defense of legal claims and/or as required by law.

At the end of this period, your Personal Data will be securely deleted or fully anonymized.

You may have the following legal rights: request access, revision, correction or deletion of your Personal Data; object to further processing; restrict processing or request portability of your Personal Data; withdraw your consent without having to provide any reasons; and/or submit a complaint to the competent data protection authority.

Please note that the exercise of these rights may be subject to limitations and/or restrictions set out in applicable laws; they may also be subject to variations or additional rights may be available to you in your country of residence or place of work.

A list of the  European Data Protection Authorities can be found here.

The UK Information Commissioner’s Office (ICO) may be contacted here: https://ico.org.uk/make-a-complaint/

The Swiss Federal Data Protection Information Commissioner (FDPIC) may be contacted here: https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html

For questions, concerns or to exercise your rights in relation to the Processing of your Personal Data, please do not hesitate to contact the argenx Privacy Office at privacy@argenx.com.

For further details on how argenx generally collects and processes your Personal Data, please consult our Privacy Policy available on our corporate website at https://www.argenx.com/privacy-policy