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 1. ← US


VIATRIS PRIVACY NOTICE




Last Updated: September 2020

Viatris Inc. and its affiliates and subsidiaries (collectively “Viatris,”
“Company,” “we,” “our,” and “us”) are fully committed to protecting the
information relating to identified or identifiable natural persons (“Personal
Data”) that we process.

This Viatris Privacy Notice (“Notice”) describes our collection, use,
disclosure, and retention of Personal Data in relation to our websites, apps,
services, and platforms, and your use of them, our marketing and provision of
products and services, our interactions with you in-person, by calling us, or by
mail, and otherwise during the operation of our business. The Notice also
explains the ways in which you may, under applicable laws, be able to control
our processing of your Personal Data and exercise other rights. This Notice does
not apply to Personal Data of members of our workforce in the context of that
relationship.

Depending on the way you interact with us, we may occasionally provide you
additional information about our processing of your Personal Data addressing
specific processing activities and circumstances. For example, where we sponsor
clinical trials or offer training or other services to healthcare providers,
separate privacy notices may apply to our processing of Personal Data for those
and other circumstances. We refer to such notices here as “Supplemental
Disclosures”. Supplemental Disclosures should be read together with this Notice.
However, in the event of any conflict or inconsistency between the terms of the
Supplemental Disclosure and this Notice, the Supplemental Disclosure will
prevail, but only for the Personal Data processing subject to that disclosure.

The Viatris subsidiary or affiliate with which you interact is, where
applicable, the data controller (or equivalent under applicable law) responsible
for the processing of your Personal Data. You can find a list of the relevant
legal entities that act as data controllers in Appendix 1 to this Notice. Such
entities may also have separate Supplemental Disclosures.

We have appointed a Data Protection Officer (“DPO”) for jurisdictions where one
is required under applicable law. However, anyone in any jurisdiction can
contact our DPO with questions about our Personal Data processing activities or
the contents of this Notice. Please see the “ Contact Us” Section below for
information on how to contact our DPO.

Anonymous, de-identified, and aggregate data, as those terms may be defined
under applicable law, are not considered “Personal Data” within the meaning of
this Notice.

This Notice is comprised of the following sections:

1.Personal Data We Collect 2.Why We Process Personal Data 3.Lawful Bases of
Processing 4.Disclosures of Personal Data 5.Cross-border Transfers of Personal
Data 6.Data Security and Retention 7.Your Choices and Rights 8.Children’s Data
9.Revisions to this Notice 10.Contact Us 11.Caafornia Disclosures 12.Appendix 1

Please note that our websites, apps, or platforms may link to content provided
by third parties that we do not control and for which we are not responsible.
When you navigate to such content, the relevant third parties may process your
Personal Data. We encourage you to read the third parties’ privacy and cookies
notices when you leave our website, app, or platform.

1. Personal Data We Collect

Viatris or third parties acting on our behalf may collect Personal Data about
you from a number of sources. We may collect Personal Data that you provide,
such as when you register for an account on our website, submit an employment
application to us, or sign up for a webinar or training session. We may also
automatically collect Personal Data as you interact with us, such through
cookies and similar technologies, including information such as collecting the
IP address from which you visited our site (see further discussion of cookies at
the end of this section). We also collect Personal Data from third party
sources, such as obtaining information about healthcare licenses from
third-party suppliers.

The types and amount of Personal Data that we collect about any particular
individual would depend on the nature of our relationship with that individual
and the purposes for which we use the individual’s Personal Data. We collect
Personal Data from different categories of individuals, including but not
limited to the following:

• Visitors to our digital properties (such as our websites and applications)
• Healthcare professionals
• Workforce members and representatives of our service providers, suppliers,
contractors, and business partners
• Researchers and members of the scientific community
• Job applicants
• Trial participants

Personal Data That You Provide

We collect Personal Data that you choose to provide us, such as when you are
registering to participate in a clinical trial, completing surveys, speaking
with our customer support agents, reporting pharmacological concerns and other
complaints, visiting our offices, or applying for employment, among other
interactions.

Depending on your relationship with us, you might provide us the following
categories of Personal Data:

• Identifiers and Contact Data, such as your name, alias, postal address, email
address, telephone number, city, state, and country of residence,
government-issued identifiers (such as passport number or driver’s license),
account name and password, health insurance number, financial account numbers,
and similar identifiers.

• Demographic Data, such as your income levels, marital status, ethnicity, sex,
gender, age, sexual orientation, national origin, disability status,
citizenship, and work authorization status.
• Health Data, such as conditions with which you have been diagnosed, symptoms
that you have experienced after taking a Viatris product, drug usage, dietary
restrictions, and other data relating to your physical, mental, or emotional
health.
• Commercial Data, such as invoices, payment terms and schedules, financial
account information, and information about services rendered.
• Biometric Data, such as facial geometry, iris patterns, and other biological
measurements.
• Professional Data, such as healthcare license numbers, current and previous
employers, current and previous salaries, educational history, information
provided on your resume or CV, and images and recordings of your likeness or
voice.
• Preferences and Survey Responses, such as your preferences regarding
communication means and your responses to surveys, including customer
satisfaction surveys.

Personal Data That We Collect Automatically

We may automatically collect information that constitutes Personal Data when you
interact with us, such as when you visit our digital properties, read our
marketing communications including emails, contact us, purchase a product from
us, apply for a job, or attend events that we are hosting, among other
interactions.

Depending on your interaction with us, we might collect the following categories
of Personal Data:

• Identifiers and Contact Data, such as device identifiers (e.g., IP and MAC
addresses, cookie identifiers, device advertising identifiers), username and
password, email address, phone number, and similar identifiers.
• Usage and Device Data, such as websites visited, browser type and version,
time zone setting and location, browser plug-in types and versions, operating
system and platform, other technology on the devices used to access our websites
and apps, volume of transferred data, location data (e.g., inferred by IP
address or obtained through GPS), and interactions with advertisements.
• Health Data, such as inferences about the conditions that you might be
experiencing based on your browsing activity.
• Commercial Data, such as details of products and services purchased or
sampled.
• Biometric Data, such as facial geometry, iris scans, and other biological
measurements.

We use cookies and related digital tracking technologies (“Cookies”) in our
emails and on our digital properties. This may involve us or third parties
collecting Personal Data about online activities over time and across third
party websites or online services. Please read our Cookie Notice for more
information about our use of Cookies. We do not currently respond to web browser
Do Not Track signals or similar mechanisms.

Personal Data That We Collect from Third Parties

We may obtain Personal Data relating to you from third parties, such as when we
obtain contact data from marketing list suppliers to support our marketing and
sales initiatives or when we obtain professional license information to confirm
information provided by healthcare providers.

The third parties from which we obtain Personal Data generally fall within the
following categories:

• Government sources
• Publicly accessible data
• Social media platforms
• Marketing list suppliers
• Advertising partners
• Analytics providers
• Payment processors
• Data supplementation suppliers
• Business partners, such as event co-sponsors

We collect the following categories of Personal Data from third parties:

• Identifiers and Contact Data, such as name, postal address, email address,
telephone number, general location (such as city, state, and country), username,
and device identifiers (including cookie identifiers and device advertising
identifiers).
• Demographic Data, such as information about income levels, age, sex, gender,
sexual orientation, national origin, and disability status.
• Usage and Device Data, such as browsing and search history and interactions
with advertisements.
• Health Data, such as information about reactions to Viatris products that are
made available on social media platforms.
• Usage and Device Data, such as websites visited, browser type and version,
time zone setting and location, browser plug-in types and versions, operating
system and platform, other technology on the devices used to access our websites
and apps, volume of transferred data, location data (e.g., inferred by IP
address or obtained through GPS), and interactions with advertisements.
• Commercial Data, such as details of products and services purchased or sampled
and inferences regarding the population segments to which you might belong.

2. Why We Process Personal Data

The specific purposes for which Viatris processes an individual’s Personal Data
differs based on our relationship with the individual. In general, Viatris
processes Personal Data for the following purposes:

• To conduct legitimate business activities, including but not limited to
marketing, promotion, sales to customers, customer support, receiving payments,
entering into contractual agreements, contracting with third party service
providers, identifying investigators for clinical trials, preventing fraud, and
procuring goods or services.
• To deliver our products, goods, or services, including to fulfil your
requested transactions and, where necessary, to confirm that you meet an
eligibility criteria if the requested product, good, or service is limited to
certain groups.
• To communicate with individuals, including responding to questions, queries,
and complaints from customers, users, and other individuals, responding to
requests for donations, sponsorships, scholarships, or charity, and informing
individuals about job opportunities with Viatris.
• To provide information and advertising, such as digital advertising or direct
marketing, about goods, services, and products that we think may be useful,
relevant, or of interest to you.
• To provide training, education, and grants, such as our training and education
programs that we provide to health care professionals or where we offer grants
to which health care professionals can apply.
• To evaluate an individual’s candidacy, such as when processing an application
for an opening on Viatris’ team or when evaluating whether to award a grant.
• To conduct research and development, including to improve existing products
and services and to develop new ones.
• To provide, maintain, develop, and improve our digital properties, including
our websites, apps, services, and platforms.
• To maintain, improve, and investigate the security of our systems and digital
properties.
• To comply with legal obligations, such as obligations relating to research,
development, pharmacovigilance, marketing, and promotion of medicinal products
and other healthcare products, and to respond to legal process or inquiries from
authorities.
• To protect the rights, interests, and safety of us, you, and any third
parties, and to exercise and defend our rights.
• To create anonymous, de-identified, or aggregated datasets. Such datasets
would not be “Personal Data” subject to this Notice. We may use anonymous,
de-identified, or aggregated datasets for any purpose.

The additional purposes for which we may process what are deemed special
categories of personal data under certain jurisdictions’ laws are as follows to
the extent relevant, necessary and permitted by applicable local law:

• Demographic data - We will use information about your sexual orientation,
race, ethnicity and disability for specific reasons, such as necessary for
clinical trials or to ensure meaningful equal opportunity monitoring and
reporting as required by some jurisdictions’ laws.
• Biometric data - We will use biometric data for specific reasons, such as
necessary for clinical trials.
• Health data - We will use health data for patient support programs and in some
cases may receive health data for clinical trials and related activities.

3. Lawful Bases of Processing

Certain jurisdictions require that we have a lawful basis to justify our
processing of your Personal Data. Where applicable, the lawful bases that
Viatris relies upon to justify a particular processing activity may differ from
the lawful basis used to justify a different processing activity. Viatris relies
on the following lawful bases to process Personal Data, as permitted under
applicable law:

• Processing necessary for the negotiation, execution, or performance of
contracts
• Processing to comply with legal and regulatory obligations
• Processing for reasons of public interest in the area of public health
• Processing in furtherance of our legitimate interests, including our interests
to conduct legitimate business activities (such as improving our products and
services, to communicate with you, to secure our systems, among other legitimate
interests)
• Processing based on your consent

We may obtain your consent to collect and use certain types of Personal Data
when we are required to do so by law (for example, in relation to our direct
marketing activities and our use of cookies). If we ask for your consent to
process your Personal Data, you may withdraw your consent at any time by
contacting us using the details at the end of this Notice. Withdrawing your
consent will not affect the lawfulness of processing based on consent before its
withdrawal.

Where required by law, we may obtain your explicit consent to collect and use
special category data (see the end of section 2 above) about you. Other legal
bases for our processing of special category data may include, as permitted by
applicable law, for scientific research, for purposes of preventative or
occupational medicine or based on a contract with a health care provider or
other health professional, for employment, social security or social protection
law, for reasons of substantial public interest, or as necessary for the
establishment, exercise or defense of legal claims.

You can contact our DPO for more information about our processing of your
Personal Data.

4. Disclosures of Personal Data

Where required by applicable law, Viatris does not rent, sell, or share Personal
Data about you with non-affiliated persons for their direct marketing purposes
unless we have your permission. Otherwise, however, we may disclose your
Personal Data to the following categories of third parties without your consent
as permitted by applicable law:

• Members of the Viatris Corporate Group, including our affiliates,
subsidiaries, and Viatris Inc. in the United States.
• Service Providers, which are entities that process Personal Data on behalf of
Viatris.
• Persons with legal rights to access Personal Data, including, as the case may
be, law enforcement agencies, intelligence services, competent administrative
and judicial authorities, and persons with validly-issued subpoenas, warrants,
or other forms of legal process; and
• Parties involved in potential business transactions, including potential
acquirers and other stakeholders in the event of a merger or legal restructuring
operation such as an acquisition, joint venture, assignment, spin-off,
divestiture, or bankruptcy.

We may also disclose your Personal Data to third parties such as social
networking and other sites if you direct us to share your Personal Data with
such sites or to other entities that do not fall in one of the above categories
with your permission.

5. Cross-border Transfers of Personal Data

Viatris operates globally and consistent with applicable laws may process your
Personal Data in jurisdictions that are not regarded as providing the same level
of protection to Personal Data as the jurisdiction in which you are based.

When transferring Personal Data across borders, we take steps to put in place
safeguards to protect such Personal Data as required by applicable laws. These
safeguards may include:

• Transferring Personal Data to recipients located in countries deemed to
provide an adequate level of protection for Personal Data including where
Personal Data originates in the European Union, to countries which the European
Commission has deemed to provide an adequate level of protection for Personal
Data; and
• Entering into agreements containing contractual safeguards, such as the
Standard Contractual Clauses that have been approved by the European Commission.

Please do not hesitate to contact us if you have any question concerning the
transfer of your Personal Data (see the “Contact Us”).

6. Data Security and Retention

Viatris implements various technical, administrative, physical, and
organisational measures to protect the security and confidentiality of Personal
Data. While we take measures to safeguard your Personal Data, we cannot
guarantee that the Personal Data we process will remain secure.

Where required by law, Viatris will retain Personal Data only for as long as
necessary to accomplish the purposes for which the Personal Data was collected
or for the period required by the applicable laws (whichever is longer).

To determine the appropriate retention period for your Personal Data, Viatris
considers the following factors:

• The volume, nature, and sensitivity of the Personal Data;
• The potential risk of harm from its unauthorized use or disclosure;
• The purposes for which we process it and whether we can achieve those purposes
through other means; and
• Applicable legal requirements.

When the retention of your Personal Data is no longer necessary for the purposes
for which it was collected or our retention of such Personal Data is no longer
required by law, we will delete, anonymize, de-identify, or aggregate the
Personal Data such that it is no longer associated with you.

7. Your Choices and Rights

Some jurisdictions have provided individuals with certain rights in relation to
the processing of their Personal Data. This is the case where you or the Viatris
subsidiary or affiliate with which you interact is located in the European Union
or United Kingdom, though these rights may be available in other jurisdictions
too. These rights are not available to everyone, and they do not necessarily
apply in all contexts. Depending on applicable law, you may have the rights to:

• Request access to your Personal Data.
• Request correction of your Personal Data (should your Personal Data be
inaccurate, incomplete, or obsolete).
• Request deletion of your Personal Data.
• Withdraw your consent to processing (where we processed Personal Data on the
basis of your consent). Please note that withdrawing your consent applies only
to future processing activities.
• Object to the processing of your Personal Data.
• Request restrictions on the processing of your Personal Data.
• Request the transfer of your Personal Data to you or a third party.
• Opt-out of certain transfers to third parties.

To exercise a right that you believe you may be entitled to under applicable
law, please contact our DPO. We may need to verify your identity before we
fulfil your request (see also the California disclosures section below if you
are a California resident).

If you feel that we have failed to comply with your request or have not
addressed a complaint that you have, you may also have the right to complaint to
the competent data protection or other regulatory authority in your
jurisdiction.

8. Children’s Data

We do not knowingly process Personal Data relating to individuals younger than
16 without the permission of the minor’s guardian, except where permitted under
applicable law. If you have reason to believe that we are processing Personal
Data relating to a minor without permission from the minor’s guardian, please
notify us at dataprivacy@viatris.com. Please note that in certain situation we
may process minors’ Personal Data for specific activities such as clinical
trials. Such processing will be subject to separate policies and procedures,
including Supplemental Disclosures.

9. Revisions to this Notice

We may update this Notice from time to time. You are encouraged to consult this
Notice on a regular basis and check the date on which the Notice was last
updated, as shown in the beginning and end of the Notice. When we make a
material change to the Notice, we will endeavour to notify you by placing a
notice on our website or we will provide notice as otherwise required by law.

10. Contact Us

To exercise your rights or make a request concerning the processing of your
Personal Data, you may contact us by:

• Emailing us at dataprivacy@Viatris.com;
• Mailing us at Head of Global Privacy, 1000 Mylan Boulevard, Canonsburg, PA
15317, United States; or
• Using the Viatris compliance line via the phone number indicated at
www.viatriscomplianceline.ethicspoint.com

11. California Disclosures

Click here for a Supplemental Disclosure for California Residents.

12. APPENDIX - List of Controllers

Click here for a table of applicable controllers and responsible entities.


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