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Consent for educational information and communications and notification of the collection and processing of personal data for this purpose

GW Pharma (International) BV (“GW”) is subsidiary company of the UK-based GW Pharmaceuticals group that develops and markets cannabinoid-based medicines. We respect individuals’ rights in relation to the privacy and the confidentiality of their personal data. We only collect and use the personal data necessary to provide you with educational information and communications, as described below. The data controller of the personal data we collect for these purposes is GW Pharma Limited (company number 03074998) with the address Sovereign House, Vision Park, Chivers Way, Histon, Cambridge CB24 9BZ, United Kingdom.

Personal data that we collect about you and why

In addition to collecting your personal data directly from you, we may also collect personal data about you from a variety of sources including from publicly available sources, online and other databases and websites, and other documents or forms that you provide in order to participate in GW-sponsored or supported initiatives, such as GW-sponsored medical education, research and development activities, or in other contexts.

GW may collect and use some or all of the following categories of personal data about you:

• personal details such as your name, age, gender and contact details;
• professional details such as your place of practice, job title, the medical field in which you are active, your professional qualifications and scientific activities (such as previous clinical trial experience, and participation in past or pending research studies with GW and other companies), publication of academic or scientific research and articles, and membership in associations and boards; and 
• details of interactions with us, such as what kind of meetings we have held, topics discussed, your knowledge of and questions you have had on 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 and routines on prescribing, routines regarding your patients and diagnosis,

We process this information in our customer databases for the purpose of providing educational information and communications, and managing our relationship with you, including planning potential collaboration, contact, and helping ensure that we provide you with information that is relevant given your expertise, interests and preferences. The legal basis for this processing is our legitimate interest in maintaining a relationship with you and to provide you with the information you have requested.

Sharing your personal data

GW may share your personal data with others, from time to time, in connection with the purpose described in this notice. In particular, we may make your personal data available to:

• other companies within the GW Pharmaceuticals group;
• third party companies with whom we may partner in connection with proposed or actual GW projects such as commercialisation, medical communication, market research, creative agency, market access;
• third party companies that supply goods or services to GW such as legal counsel, auditors and IT service suppliers;
• other third parties pursuant to a court order, to protect the interests of GW, or where otherwise required by law or legal process; and actual or prospective purchasers of GW businesses in the event of a sale, merger or acquisition

Sharing your personal data as described above may involve transferring it to countries, including countries outside of the EU/EEA, whose data protection and privacy laws may not be equivalent to, or as protective as, those which exist in your country of residence. However, in accordance with applicable law, GW implements measures such as standard data protection clauses to ensure that any transferred personal data remains protected and secure.

Securing and retaining your personal data

GW will take appropriate technical and organisational security measures to protect your personal data consistent with applicable privacy and data security laws. When GW retains a third-party service provider, that provider will be carefully selected and required to use appropriate measures to protect the confidentiality and security of personal data. GW retains your personal data only for as long as we continue to have a relationship with you, unless a longer retention period is required or permitted by law.

Your rights

You may contact GW to request access to personal data that we process about you and that we correct inaccurate data and complete any incomplete data. In accordance with the conditions and requirements of applicable law, you may object to our processing your personal data and request that we erase personal data about you, restrict processing of such data, and transmit your personal data to you or another data controller. Should you wish to exercise these rights or if you have any questions regarding this notice or prefer that GW not contact you again, please let GW know by contacting us at info@gwpharm.com. You may lodge a complaint with a supervisory authority if you consider that our processing of your personal data infringes applicable law.