Privacy Policy | BeiGene

Effective date of last update: 10 November 2023

Click here to download or print a copy of this Website & General Privacy Policy.

BeiGene is committed to respecting and protecting the privacy of your personal information. “Personal information” is information related to you that can potentially be linked back to you.

The data controller of your personal information (i.e., the entity determining how and why your personal information is used) under this Privacy Policy is BeiGene, Ltd., unless:

Another privacy policy or notice mentioned a different entity, or
You are dealing with or working for another BeiGene entity.

In such cases, the other entity mentioned or the one you are dealing with or working for will be the controller. If you have questions or complaints and want to reach the data controller or its data protection officer, please see the “Exercising your rights” section below.

This Privacy Policy covers personal data that is provided to, or received by, BeiGene, Ltd. and/or its subsidiary companies (“BeiGene”, “we”, “us”, “our”) and is directed at:

People who use BeiGene’s websites, apps, facilities, products, and services (excluding participants in a clinical study*);
People who work or worked with BeiGene, like clients, partners, suppliers, consultants and contractors; and,
Any members of the general public who communicate with us.

*- If you are a participant in a BeiGene sponsored clinical study or other research and want to know about your personal information or your rights, please see the copy of the Patient Information Sheet and Informed Consent Form that you received.
This Privacy Policy explains how we use your personal information and how you can use your rights.

Here are a few important points to keep in mind as you read this:

Some parts of this Privacy Policy may not be applicable to you based on where you live or the type of personal information we maintain about you. For example, if we are not making payments to you, we will not need your banking information.
In certain circumstances, other privacy policies or notices may add to or replace this one. If that happens, the other policy or notice will be the one that applies to how your personal information is handled.
Our websites, web portals, mobile applications or other digital services (together, our “websites”) may contain links to websites that we do not run, control or endorse. When you go to those websites, we are not responsible for the protection and privacy of any information you provide. We suggest reading their privacy policies and reach out to them directly for information about their privacy practices.

Our websites are not meant for individuals under the age of 16 years old (“children”). We do not knowingly collect personal information directly from children through our websites, so if you are a child, please do not use our websites or provide any information to us through our websites or otherwise, unless we have first obtained a parent or guardian’s consent, where applicable.

We aim to regularly update this Privacy Policy to reflect our practices. Therefore, we recommend periodically reviewing this Privacy Policy. In case of material changes, we may take steps to notify you before they become effective.

Effective date of last update: 10 November 2023

We may collect and use your personal information in different situations. For example, when you participate in BeiGene research, take our drugs or therapies, or visit our websites or offices. Depending on your interactions with us over the past twelve (12) months we may have collected:

Certain information (such as health information) may be considered more sensitive under applicable laws. We do not routinely collect or otherwise use this information (except as part of our patient support programs), but where we do, we will:

only collect this information when needed;
take appropriate measures to protect and process your sensitive personal information; and,
provide notices and/or obtain your explicit consent prior to processing your sensitive personal information where required by applicable laws.

We usually get your personal information directly from you, e.g., when you contact us, fill out a form, buy our products, provide services to us, register an account or ask for marketing materials and information.

Sometimes, we may obtain personal information about you from other sources, such as where you have instructed a third party to send information to us, or where we have an arrangement with our research partners, collaborators and service providers. We may also gather information from publicly accessible sources such as government records, websites, social media, and other digital platforms.

If you use our websites, we may collect information from your computer or other device through our use of cookies and other data collection technologies. For more information, please see our Cookies Policy.

How we handle your personal information depends on why we collected it, e.g., it is determined by your interactions with BeiGene, applicable laws and our own procedures and requirements, as outlined below:

“Profiling” means analysing someone’s interests, habits, behaviours and other characteristics to predict or make decisions about them. “Automated decision-making” is when a computer program, automated system or algorithm makes that prediction or decision. For example, in order to assess the suitability of third parties we work with, we may assess their experience, complete other due diligence on them, and manually compare this against our requirements. However, no profiling, prediction or decision is made through fully automated means without human review.

We keep your personal information for as long as it is necessary for the reasons explained in this Privacy Policy. Sometimes, we keep it for longer to comply with our legal obligations. To decide how long we keep it for, we consider the amount, type and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, why we need it, if we can do the same without it and all applicable global legal, regulatory, and compliance requirements.

When you sign up for an email alert or newsletter, we will keep your information until you unsubscribe. If you make requests, we will keep that information until we complete the processing of your requests. If you ask to unsubscribe, we will keep a record of your request for as long as is necessary to demonstrate we complied with that request.

We will also keep your personal information for:

The relevant period in the statute of limitations, if needed for evidence purposes;
Complying with periods set by law, e.g. in relation to commercial, legal, compliance and regulatory matters

BeiGene operates in many countries around the world and your personal information may be accessible to or shared within the BeiGene group and with third parties in different countries as explained in the SHARING YOUR PERSONAL INFORMATION section of this Privacy Policy. The laws in certain countries may not provide the same level of protection as the laws in your country or region. When that is the case and as required by applicable laws, we take steps to make sure your information stays safe e.g., entering into contracts with recipients of your information or implementing additional data safeguards.

Whilst we do our best to protect your information, we cannot guarantee its absolute security. Be vigilant in deciding what information you share with us when you send information online.

We may share your personal information within the BeiGene group and with the third parties described below. What we share, why we share it and the safeguards we implement depend on who these third parties are and where they are located. We do not, however, sell the personal information that we collect.

You have the choice not to give us your personal information; however, that might mean you cannot maintain your relationship or interactions with us or use certain services, e.g., patient support services.

Under certain laws such as the General Data Protection Regulation (GDPR), California Consumer Privacy Act of 2018 (CCPA), California Privacy Rights Act of 2020 (CPRA) or China’s Cybersecurity Law (including its implementing regulations and national standards), you may have the following rights with respect to your personal information, depending on the law applicable to your location:

Right of access. You can ask us for clear, transparent and understandable information on how we handle your personal information, including information on where and who we share it with, and request copies of it.
Right to rectification. You can ask us to rectify information you think is obsolete or inaccurate and or request that it be completed if incomplete.
Right to deletion. You can also request we delete your personal information in certain circumstances.
Right to withdraw your consent. If we process your personal information based on your consent, you have the right to withdraw your consent, and it will not affect the lawfulness of what we did before.
Right to opt out of future communications. You can choose to opt out of (unsubscribe from) certain future communications, such as marketing emails.
Right to data portability. You may have the right to ask that we transfer the information provided to us from one organization to another or give it to you.

Depending on where you live and where the BeiGene office handling your personal information is located, you may have additional rights related to your personal information. For further information, please see the relevant state-specific section.

If you want to exercise your rights, you can email us at privacy@beigene.com.

We will respond to your requests within the time period prescribed by applicable laws. Sometimes, we might need to confirm your identity to make sure it is really you asking and to keep your information safe. We will let you know: (i) when your request is completed, (ii) if we deny your request (because, for example, an exemption applies), or (iii) if there is a fee associated with processing your request.

You can choose someone to act on your behalf, but we will also need to check their identity and make sure they have permission to act on your behalf. If we cannot verify them, we might not be able to fulfill the request.

If you believe that BeiGene has mishandled your personal information or has breached your rights, you may have the right to contact your local data protection authority to file a complaint. But you can also let us know by sending an email to privacy@beigene.com. We take your concerns seriously.

We will not discriminate against you for exercising any data subject right you have under the law.

GENERAL CALIFORNIA PRIVACY NOTICE

If you are a Californian resident and interact with BeiGene, you can find details about how we collect, use, and disclose your personal information in the relevant sections of this Privacy Policy.

Specifically:

In the past twelve (12) months we may have collected and shared various types of personal information about you as described in the in the “CATEGORIES OF PERSONAL INFORMATION PROCESSED BY BEIGENE” section of this Policy. For Californian residents in particular, we further collect audio, electronic, visual, thermal, olfactory, or similar information and inferences drawn from other personal information.
In the past twelve (12) months, we may have collected and shared sensitive personal information about you for our business needs. “Sensitive Personal Information” is defined as being a subset of personal information which includes but is not limited to government identifiers (e.g., social security numbers), an account log-in, financial data, debit card or credit card number with any required security code, password or credentials allowing for access to an account, the precise geolocation, contents of mail, email or text messages, genetic data, biometric information, information concerning a consumer’s health, sex life or sexual orientation or information about racial or ethnic origin, religious or philosophical beliefs or union membership.
We get this information from different sources as explained in the “SOURCES OF INFORMATION” section of this Policy.
We may share your information with different groups and for various purposes as described in the SHARING YOUR PERSONAL INFORMATION section of this Policy.
We collect your information for various reasons which you can learn more about in the WHY WE PROCESS YOUR PERSONAL INFORMATION section of this Policy.
We will not use your information for anything other than the reasons we have explained in “WHY WE PROCESS YOUR PERSONAL INFORMATION” unless we let you know first.
The “Sensitive Personal Information” collected as specified above will be disclosed for the following purposes:
- To provide the services or information reasonably expected when you ask for them;
- To meet our reporting and other legal requirements we are subject to;
- To protect against security incidents and investigate issues with your personal information;
- To defend against malicious or illegal activities aimed at our business;
- To ensure the safety of people;
- For short-term, transient use, e.g., showing you adverts during your current interaction with us (but we will not share your information or use it to track you);
- To get help from others who do tasks for us e.g., providing customer service, payment processing or data analysis; and
- To check or maintain the quality or safety of our products or services and make them better.

We do not use or share sensitive personal information for purposes that require us to offer you a chance to opt-out.

We do not sell personal information of California consumers, nor do we share personal information of California consumers for cross-context behavioral advertising purposes.

You can use your data subject rights to find out what personal information we have about you; request access to it, ask for it to be deleted or corrected as described in YOUR CHOICES AND RIGHTS. You can do this by sending us an email at privacy@beigene.com or by calling us toll-free at (888) 344-1789. Californian residents can also use a web form provided at this link to exercise your rights.

Some of the personal information that we collect may not be covered by the CCPA because it is regulated by other laws. We will not discriminate against you for exercising your data subject rights. For instance, we will not refuse you goods or services to you, charge you different prices, or offer lower quality products because you exercised your data subject rights.

We are required to comply with the European Union’s and the United Kingdom’s General Data Protection Regulations (“GDPR”), Switzerland’s Federal Act on Data Protection (FADP) and other local laws when handling certain personal information we collect. The specific BeiGene entities that collect your personal information are responsible for it. If you are not sure who the Controller for your information is, please reach out and ask us.

Special category data

We may process special categories of information (e.g., personal data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, sexual orientation and genetic, biometric and health information) in the following situations:

Where you give us your explicit consent;
For scientific research purposes;
When it is required or permitted by law; and
For other legal reasons, e.g., the exercise or defense of legal claims

If we need to collect your personal information by law or under the terms of a contract we have with you and you do not provide the requested information, we may not be able to perform the contract we have, or are trying to enter into, with you.

Data transfers

If the recipient country has not been deemed by the EU/EEA, UK, and Switzerland to have adequate privacy protections, we rely on other safeguards (e.g., the EU’s standard contractual clauses or the UK’s international data transfer agreement) as well as technical controls, like encrypting the data and limiting access to specific individuals, to make sure your rights are still protected in these other countries.

If you want more details about how we use these safeguards, please contact us.

Your rights

In addition to the rights outlined in the YOUR CHOICES AND RIGHTS section, you have the following additional rights:

Your right to restriction of processing. You can ask us to restrict how we use your personal information for a limited period of time, in certain circumstances.
Your right to object to marketing. You can opt out of receiving our marketing communications anytime by using the unsubscribe option or preference center feature in any marketing email you receive from us. However, we may still send you emails related to our relationship or specific transactions even if you unsubscribe from marketing emails.
Your right to object to processing. You can also object to how we process your personal information. In this case, we will not process your information unless we have compelling legitimate grounds for the processing that override your interests and rights e.g., compliance with a legal obligation or for the establishment, exercise, or defense of legal claims.
Rights in relation to automated decision-making including profiling. Under the GDPR and the UK GDPR, you have a right to request a human review of an automated decision, if your personal information is used to make a prediction or decision reached by solely automated means.

Under the GDPR, the exercise of these rights may be limited or delayed dependent upon the legal basis for processing the data, for example:

Cookies, pixel tags, and other trackers (hereinafter “Cookies”) are small files that websites and applications use to store or retrieve information on your browser or your device (computer, tablet, mobile, etc.) when visiting our online services. They help websites remember your preferences and improve your browsing experience.

When you visit our websites for the first time (or after deleting Cookies), we will ask for your permission to use cookies. You may choose to accept all Cookies, select specific types of Cookies, or reject all Cookies (other than necessary Cookies). Cookies do not identify you personally; they identify the device you are using. They help us understand your browsing activities in order to recognize the device later on in order to improve the browsing experience, save your preferences and make your online experience better.

If you want to learn more about cookies and see which ones are on your device, you can visit websites e.g., www.aboutcookies.org or www.allaboutcookies.org.

The exact cookies we use varies depending on the website or application you are viewing/using. We may use the following types of cookies:

Strictly Necessary Cookies: These cookies make sure our websites work properly. They help with security, make browsing easier and display webpages correctly. You may disable these in your browser settings, but it might affect some website functions. You will still be able to navigate the websites, though.
Performance Cookies: These cookies help us understand how visitors use our websites to improve them. They collect information about things like the number of visitors, where they came from and which pages they visited.
Social Media Cookies: These cookies allow you to interact with social plugins on our websites and share content on social networks; and
Targeting (Advertising) Cookies: These cookies help us show you specific advertisements, measure how effective the ads are and tailor content to your interests and browsing behaviour. Such Cookies may track you over time and across websites (such as if you visit our websites multiple times or visit multiple BeiGene websites).

While most Cookies do not log your Internet Protocol (IP) address (a number that identifies your computer by your Internet Service Provider), certain Cookies use this information to do a general geolocation check to ensure, for example, that you are directed to the version of the website that applies to your location. Additionally, our systems need your IP address in order to route information (such as the images on the website) back to you. We may also use IP addresses to communicate with or block visitors who fail to comply with our Terms of Use.

For targeted (advertising) cookies, we respond to “Do Not Track” signals from your browser t. You can learn more about “Do Not Track” signals, here: https://allaboutdnt.com/.

If you have questions or concerns about this Privacy Policy or how we do things, do not hesitate to reach out to us by emailing privacy@beigene.com.

We will endeavor to respond to your request as soon as reasonably possible in compliance with applicable laws.

To keep your information safe, we will check your identity before granting access or making changes. Keep in mind that even if we remove or change your information, there may be residual information in our records.

We are committed to being accessible to everyone including those with disabilities. If you need this document in a different format, please contact us at privacy@beigene.com.

Effective date of last update: 10 November 2023

Click here to download or print a copy of this Adverse Events and Products Complains Privacy Policy.

BeiGene is committed to respecting and protecting the privacy of your personal information. We usually do not collect personal information of patients who use our products. However, sometimes we need it to meet our reporting obligations and to monitor the safety and quality of our products. Personal information is information related to you that can potentially be linked back to you.

The data controllers of your personal information (i.e., the entity determining how and why your personal information is used) under this Privacy Policy are:

BeiGene, Ltd., for overseeing global safety and product quality monitoring and reporting,
The BeiGene entity or business partner assisting your specific country or region, and
Other BeiGene entities or business partners obligated to submit these reports to the regulatory authorities in different countries or regions.

If you have questions or complaints and want to reach the data controller or its data protection officer, please see the “Exercising your rights” section below.

This Adverse Events Privacy Policy is for those individuals who provide personal information to or whose personal data is provided to BeiGene, Ltd. and/or its subsidiary companies (“BeiGene”, “we”, “us”, “our”) in the course of a product complaint or an adverse event report*.

*- If you are a participant in a BeiGene sponsored clinical trial or other research and have questions about how your personal data is handled or your rights in relation to that research, please see the copy of the Patient Information Sheet And Informed Consent Form that you received.

* An “event reporter” is the individual that reported the adverse event or product complaint to BeiGene and the “event subject” is the individual that suffered the adverse event or project complaint. They may be the same person.

For more information about BeiGene personal data processing for other purposes, please refer to our Privacy Policy.

We collect your personal information because we are legally required to and based on our legitimate interests to make our products safe and high-quality. These obligations are independent of your age.

We aim to regularly update this Privacy Policy to reflect our practices. Therefore, we recommend periodically reviewing this Privacy Policy. In case of material changes, we may take steps to notify you before they become effective.

Effective date of last update: 10 November 2023

We process the personal information you give us or collected by us that is relevant to your adverse event report or the product complaint. Within the last twelve (12) months, this may have included:

If you are a health care professional who is reporting an adverse event or product complaint, we may also gather information about your professional qualifications.

The potential recipients are described in the SHARING YOUR PERSONAL INFORMATION section of this Policy.

We use your personal information to handle, monitor, and if necessary, report your adverse event report or product complaint in line with our legitimate interests and/or legal obligations, and to protect your vital interests.

We also use it to make our future clinical trials and medical products safer and comply with our legal and regulatory obligations.

If you are part of a BeiGene access program, we use your data to keep a good record of your medical history for the safety of your future treatments with our products in line with our legitimate interests and/or legal and regulatory obligations.

If at any point you exercise privacy rights, we will use your data in order to address that request, in line with our legal obligations.

We process this information to follow the law and our contracts, and it helps us monitor and/or report adverse events with the quality of our products, as well as our legitimate interest to monitor, take into account and address any complaint regarding our drugs or therapies.

We keep your personal information for as long as it is necessary for the purposes outlined above, unless the law states we have to keep it for longer.

In particular:

in the case of an adverse event report, we will keep your personal information relating to your report for at least 25 years.
in the case of a complaint regarding one of our products or therapies, we will keep your personal information relating to your report for at least 25 years.

In addition to this, BeiGene may keep your personal information for longer during:

the statute of limitations, if needed for evidence purposes;
the applicable legal retention periods, in particular regarding regulatory matters, or any other mandatory retention period (such as legal hold or investigation).

Whilst we do our best to protect your information, we cannot guarantee its absolute security. Be vigilant in deciding what information you share with us when you send information online.

Right of access. You can ask us for clear, transparent, and understandable information on how we handle your personal information, including information on where and who we share it with, and request copies of it.
Right to rectification. You can ask us to rectify information you think is obsolete or inaccurate and or request that it be completed if incomplete.
Right to deletion. You can also request we delete your personal information in certain, limited circumstances.
Right to withdraw your consent. If we process your personal information based on your consent, you have the right to withdraw your consent, and it will not affect the lawfulness of what we did before.
Right to data portability. You may have the right to ask that we transfer the information provided to us from one organization to another or give it to you.

If you want to exercise your rights, you can email us at privacy@beigene.com.

We will respond to your requests within the time period prescribed by applicable laws. Sometimes, we might need to confirm your identity to make sure it is really you asking and to keep your information safe. We will let you know (i) when your request is completed, (ii) if we deny your request (because, for example, an exemption applies), or (iii) if there is a fee associated with processing your request.

We will not discriminate against you for exercising any data subject right you have under the law.