Privacy notice
This privacy notice (this “Notice”) is provided by Norton (Waterford) Limited, trading as Teva Pharmaceuticals Ireland (“Teva Ireland”) and its affiliates in the Republic of Ireland (“ROI”) (collectively, “Teva”). Teva is referred to in this Notice as “we”, “us” and “our”.
This Notice describes why you can trust us with your personal data, how we use your personal data, including how we share it, and your data protection rights which include a right to withdraw consent. This Notice also includes specific information for Website Users and Cookies.
How we use your personal data
This Notice applies to the processing of your personal data when:
- we communicate with you by using email or similar means of communication,
- we meet online by using third-party teleconferencing tools, or
- you visit or use our ROI websites and other digital properties (such as apps) or platforms (each, a “Site”) and each such Site may have an additional specific privacy notice.
We will only process your personal data in accordance with the applicable laws and when we have a legal basis for the processing as identified below. We will use your personal data for the purposes for which it was collected, unless we reasonably consider that we may process it for another purpose which is compatible with the original purpose. We will notify you in advance if we change or add to those purposes and seek your consent, if necessary by law.
We adopt stringent physical security and robust information collection, storage and processing practices beyond the reasonable measures required by law to secure your personal data and to prevent from accidental loss or unauthorised access, use, alteration, or disclosure, including access controls.
We keep your personal data no longer than necessary in accordance with retention periods as part of our Records and Information Management policy. In most cases, for contractual and financial information, including any complaints, customer training or correspondence, the relevant retention period is no more than 11 years. In the pharmaceutical industry there are a number of instances where personal data is required to be kept by law for a period of time which may be shorter or longer than 11 years. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the data, the potential risk of harm resulting from its unauthorised use or disclosure, the purposes for which we disclose the personal data and whether we can achieve those purposes by other means and any applicable legal requirements (whichever is the longest). We will take reasonable steps to delete personal data no longer required or we take appropriate steps to anonymise (irreversibly remove any identifiers from) your personal data. We describe some of the retention periods in the specific sections which may be applicable to you below. If you would like further information, please Contact Us.
We collect personal data about you directly during our interactions with you or in some cases indirectly through a third-party service provider, who may also be a joint controller. This may include: your name, surname, your business address, email address and phone number necessary for the performance of a contract with you, to meet legal obligations or where we have a legitimate interest.
We may also process your personal data where we have a legal obligation such as
- tax, accounting, regulatory, pharmacovigilance, advertising and compliance and other legal obligations, or,
- to detect, investigate, prevent or report activities that may violate our policies or be illegal, such as fraud, terrorism, misrepresentation, security incidents or crime, or,
- in the case of dispute resolution, legal claims, compliance with legal and self-regulatory obligations, and investigative purposes deemed necessary (including disclosure in connection with regulatory queries, legal process or litigation), maintenance of records of any consents, (including preferences or other settings to enable us to comply with data protection law), or,
- for due diligence processes such as prior to setting up a trading account, or,
- for mergers and acquisitions in relation to our group companies.
We also have a legitimate business interest in processing your personal data for managing our business, the promotion of our products, services and events, the management, operation and improvement of our Sites, communication and business. We may use techniques such as artificial intelligence to process and analyse data contained in records of our communications, online meetings with you, including your voice and image, and other interactions with you, survey responses (where applicable), your marketing preferences, including any consents you have given us.
Also, depending on your interaction with Teva, we may collect additional personal data for other purposes. Please expand the section most relevant to you.
Sharing your personal data
Generally, we may share your personal data with the following categories of recipients (in all cases, only when necessary to fulfil their functions):
- external consultants, professional advisors and agents;
- other companies in the Teva group of companies worldwide located in the European Economic Area and beyond such as the United Kingdom, India, Israel, and the USA, who may provide group services such as HR, Finance, Compliance, Legal, Marketing, and IT. You can view a list of all the Teva affiliates at the following website: https://www.tevapharm.com/contact-us/. We rely on adequacy decisions for the transfer of personal data to countries outside the European Economic Area (“EEA”) countries such as Israel and the United Kingdom, which are decisions by the European Commission that having assessed the adequacy of the data protection laws in the relevant countries, the European Commission deems the level of protection in those countries as broadly equivalent to that in the EEA For transfers to India and to the United States we generally rely on standard contractual clauses which contractually ensure the same degree of protection to your personal data as that which you would expect by law in the EEA.
- third party service providers which process your personal data on behalf of Teva and who are bound by contractual obligations to keep your personal data confidential and appropriately secure to the same standard as could be expected in the EEA, or regarded as adequate by the European Commission, such as:
- various IT support, website hosting, CRM hosting, event management and analytics providers;
- investment houses for the purposes of benefits management, training providers, inquiry and other database hosting and support; and
- various HR, finance, travel and administration services;
- government authorities (including tax authorities), regulatory agencies including European Medicines Agency or equivalent locally, law enforcement officials and pharmaceutical self-regulatory bodies such as EFPIA in Europe;
- in relation to the performance of our relations, the protection of our legitimate interests or the compliance with our legal obligations, we may disclose your personal data to service providers such as banks, postal service providers, lawyers, auditors, etc. When dealing with such providers, we require them to strictly comply with all applicable data protection rules and laws, as well as the specific rules applicable to their activities and the protection of the information they process in the course of such activity;
- in the event that the business is sold or integrated with another business, potentially our advisers, any prospective purchaser’s advisers and any new owners of the business and third parties (and their advisors) with whom we merge with or acquire in future.
Your Rights and withdrawing consent
You may be entitled under the applicable law to ask Teva for a copy of your information, to correct it, erase or restrict its processing, or to ask us to transfer some of this information to other organisations. You may also have rights to object to some processing (in particular, where we do not have to process the information to meet a contractual or other legal requirement, or where we are using the information for direct marketing). These rights may be limited in some situations – for example, where we can demonstrate we have a legal requirement to process your personal data.
Where you have consented to the processing of your data, you may also tell us that you wish to withdraw your consent at any time.
You have a right to opt-out or change your preferences for any direct marketing, such as emails promoting our products, services and events at any time. You can do this by contacting us using the details set out below. For certain Sites, you may also have an ability to change some marketing preferences online or in-app.
You may be resident in a country which affords similar privacy rights to those described above. If you have any concerns about how we process your personal data or wish to exercise any of your rights you may have or wish to obtain other information, you can contact us using the details set out below.
Contact Us
If you have any concerns or questions about how we process your personal data or you wish to exercise any of your rights or obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with the Teva Data Protection Office by contacting us:
- for the EU, Switzerland or UK, please write to our Data Protection Officer at Teva Europe EUPrivacy@tevaeu.com
- for the United States, write to USPrivacy@tevapharm.com
- for anywhere else, please write to IMPrivacy@tevapharm.com
The data controller for personal data gathered by or on behalf of Teva depends on your interaction with the relevant ROI company. For personal data gathered by Teva Ireland, the data controller is Norton (Waterford) Limited (Company No. 100363) whose registered office is Unit 301 IDA Industrial Park, Cork Road, C Waterford, Waterford; for personal data gathered by Tosara Pharma Ltd, the data controller is Tosara Pharma Ltd (Company No. (28434)) whose registered office is Unit 301 IDA Industrial Park, Cork Road, Waterford, Ireland; and, for personal data gathered by Norton Creams Limited, the data controller is Norton Creams Limited (Company No. 744193) whose registered office is Unit 301, IDA Waterford Industrial Park, Cork Road, Waterford, Ireland.
We hope that we can satisfy any queries you may have about the way in which we process your personal data. If you have unresolved concerns, you also have the right to complain to the Data Protection Commissioner in Ireland at https://forms.dataprotection.ie/contact or the relevant data protection authority in your country (a list of EU data protection authorities is available from here.
January 2026
1. What information do we collect?
- title and full name, job role, principal practice address, your institution or employer, work email address, personal identification numbers (such as any ID from IQVIA),
- personal bank account and other related information and financial information for any fees for service contracts or fees, expenses and the like undertaken through a consulting or personal services company, including due diligence and conflict of interest checks,
- the value of applicable direct or indirect transfers made to you by Teva or its agents whether reimbursed or not,
- information regarding products prescribed or used or services provided by us where you are the treating physician,
- events you registered for and participated in, and your dietary requirements (if any), event participation, or sponsored attendance at events, and,
- your interests and preferences, professional and employment-related information (including professional titles, employment institutions, credentials and interests, qualifications, speciality, experience, publications and other information related to your profession).
We may also process account usernames and passwords for which you have registered with us.
In addition, we collect from third party sources: publicly available sources such as public registers of healthcare professionals (such as HSJ), published journal and event materials, and information from the websites of healthcare professionals or their employers. We also use third party data providers to enhance our knowledge of the healthcare sector. This data will further include information about your role(s), your qualifications, your specialty, your employer, your experience, your publications and other information related to your profession.
2. Why do we collect it?
We process your personal data where we might be contemplating entering into a contract together such as inviting you to symposia, congresses, seminars, debates and other events, to carry out or engage in market research, scientific cooperation or other research activities to better understand our markets and/or increase our expertise, or in relation to funding arrangements with your institution, or to assess and analyse your interests and experience based on information our representatives collect during calls or visits.
We also use your personal data to tailor our communications to you in relation to products, service and events based on your expertise and professional interests.
We may also process your personal data to carry out and follow-up training or to respond to your queries or other correspondence you have submitted through our Sites.
3. What legal basis do we rely on for the data processing?
In many cases we are processing your personal data when it is necessary for the performance of a contract with you.
We have a legitimate business interest in processing your personal data for the prescription, order and sale of medicines, or, to otherwise manage our business relationship with you, such as in the marketing and promotion of our products, service and events, as well as our mutual interest in certain therapeutic areas for the continuing medical education of the healthcare profession and the legitimate exchange of scientific information.
For direct email communications we obtain your consent in the first instance, unless otherwise permitted by law.
To opt out of direct email communication, please Contact Us.
4. How long do we hold it?
The retention period for your personal data will depend on the activity. As stated above, generally we will keep contract and financial information for up to 11 years. In addition, we will keep:
|
Type of Personal Data |
Retention Period |
| Call records | Up to 3 years from the last date of contact |
| GxP training | Up to 6 years |
| Technical support when accessing our Sites | Up to 4 years |
| Medical information and educational grants | Up to 7 years |
| Interactions through trade associations with other pharmaceutical companies | Up to 7 years |
| Regulatory Submissions | Up to 21 years |
| Product Samples | Up to 6 years |
| Investigation and Audit | Up to 8 years |
| Promotional Materials | Up to 7 years |
| Market Research | Up to 4 years |
| Investigator Initiated Studies | Active + 25 years |
| Events and Exhibitions | Up to 4 years |
1. What information do we collect?
We process technical usage information when you visit or use our Sites. The data we collect may include device and network activity information, such as your device type, IP address, device or user identifiers, operating system, internet service provider, the date and time of your website use, information about the links, emails or features or content you interact with, and other log information. We also may receive error-reporting information in the event of a technical error, including the device or software type and version, the time the error occurred, the feature being used, the state of the device or software when the error occurred, and any communications or content provided at the time the error occurred, your online preferences, selections and interests collected by way of technical usage information. We also determine Site traffic sources to understand how users arrive at the Site.
For Sites where you create an account (for example to access pharmacy ordering), in order to manage your account we may collect information which identifies you, including your contact details and an account username and password, and details of the business or organisation linked to the account.
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a Site. We use cookies on the Sites to collect information about you and store your online preferences. Cookies are then sent back to the Site when you return to it: this is useful because it allows the Site to recognise your device. To find out more about cookies please visit www.allaboutcookies.org.
We also use other forms of tracking technology (such as web beacons, pixels and, in apps, software development kits, usually referred to as “SDK”s) which serve a similar purpose to cookies. When we talk about cookies in this Notice, this term includes these similar technologies.
We use YouTube API services to display videos on our Sites. This third-party service has separate and independent privacy notices and/or Terms of Service:
- YouTube API Services Terms of Service (https://www.youtube.com/t/terms)
Your use of a Site may result in some cookies being stored that are not controlled by us. This may occur when the part of the Site you are visiting makes use of a third-party analytics or marketing automation/management tool or includes content displayed from a third-party website, for example, LinkedIn or Facebook or Google Analytics, see Google Privacy Policy (https://policies.google.com/privacy)
You should review the privacy and cookie policies of these services to find out how these third parties use cookies and whether your cookie data will be transferred to a third country.
2. Why do we collect it?
We use cookies and other forms of tracking technology to allow us to manage, operate and improve our Sites, communication and business, which includes keeping them up to date and relevant, to develop our business and to inform our marketing strategy. This includes customer research and benchmarking, determining the effectiveness of and optimizing our content and advertising, enhancing their relevance to various audiences, analysing our offerings and facilitating their functionality.
We use web beacons to give us an indication of the usefulness of the emails we send to you such as whether an email was opened, clicked on or sent to spam, time stamps of the above actions, and what device was used. We may combine this information with your contact information personal identifier to personalise our messaging to you through our sales reps, emails, mobile or web channels and evaluate the quality of our messaging to you, customer research and benchmarking. If you would like to avoid web beacons all together in your emails, you may refer to your settings in your email reader program and disable the functionality that enables remote images to load and by refraining from clicking on links or refer to the relevant consent in our cookie management platform.
Below you can find more information about the cookies we use and the purposes for which we use them:
Strictly Necessary Cookies
These cookies are necessary for the Site to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Site will not then work.
Functional Cookies
These cookies enable the Site to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. These can then be used to provide you with an experience more appropriate to your selections and to make your visits to the Site more tailored. The information these cookies collect may be non-directly identifiable. If you do not allow these cookies then some or all of these services may not function properly.
Performance Cookies
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Site. We use these cookies to help us understand how users arrive at the Site, browse or use the Site and highlight areas where we can improve such as navigation, user experience and marketing campaigns. They help us to know which pages are the most and least popular and see how visitors move around the Site. Where these are used in emails, we use them to understand whether an email was opened, clicked on or sent to spam, time stamps of the above actions, and what device was used. This helps us to understand your level of interest and engagement with the information we send to you. The data collected can be combined with other data we collect to improve how the Site works and the quality and relevance of the information we sent to email recipients. For example, we use Google Analytics to better understand how users use the Site. If you do not want Google Analytics to be used in your browser, you can install this Google add-on: https://tools.google.com/dlpage/gaoptout?hl=en_GB.
All information these cookies collect is aggregated and therefore may be non-directly identifiable. If you do not allow these cookies we will not know when you have visited our Site and will not be able to monitor its performance.
Targeting Cookies
These cookies are used to deliver adverts more relevant to you and your interests, on our Site or other websites. These cookies may be set through our Site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They are also used to limit the number of times you see an advert, as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with our permission. They remember that you have visited the Site, and this information is shared with other organizations such as advertisers. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
Social Media Cookies
These cookies are used when you share information using a social media sharing button or "like" button on our Sites, or when you engage with our content on or through a social site such as LinkedIn or Twitter. These cookies collect information about your social media interaction with the Site, such as whether you have an account with the social media site and whether you are logged into it when you interact with content on the Site. This information may be linked to targeting/advertising activities.
3. What legal basis do we rely on for the data processing?
The legitimate basis for using cookies is your consent which is given when you click “yes” or “OK” to a cookie banner or pop-up on a Site.
Where applicable, we may rely on the communications exemption where the sole purpose is to identify communication endpoint, or to allow data items to be exchanged in their intended order. We may also rely on the “strictly necessary” exemption.
You may access and change your cookie preferences at any time by accessing the Cookie Settings link in the footer of this Site, and in case of email tracking you may refer to your settings in your email reader program.
4. How long do we hold it?
For technical support when accessing our Sites, we will keep your personal data for up to 4 years.
Teva websites use different cookies, so the maximum expiry periods might differ but generally they expire within 24 months. You can check the cookie expiration date in the Cookie Preference Centre by accessing the Cookie settings link in the footer of this Site.
1. What information do we collect?
When you engage with us as a customer/customer’s personnel, we will process your personal data, including your name, personal identification number, business contact details, business bank account details and other related information and business financial information. We will also maintain order/payment data, survey responses where applicable, and other appropriate records of our interactions with you.
We may also collect additional personal data when you create an account (to access pharmacy ordering, for example) or when pharmacies or wholesalers otherwise order products or services.
We will process your personal data if one of our employees has declared a potential conflict of interest (i.e. any situation in which personal, social, financial, political or other interests are placed before those of Teva) that concerns you.
2. Why do we collect it?
In addition to processing your personal data for records of our interactions for orders for products, purchases, contracts, payments, financial information, and the provision of services for planning, conducting and managing our business, we may process your personal data for conflict of interest, anti-bribery due diligence checks or trade sanctions checks.
We may share your personal data with administrative, consultancy and logistical support service providers. If you are a pharmacy customer, we may also share your personal data with wholesalers.
3. What legal basis do we rely on for the data processing?
We process your personal data because it is necessary for the performance of a contract with you, or you have requested us to take steps prior to us entering into a contract together, or, in particular, to fulfil any of our obligations owed to you under such contract such as to manage your orders, arrange the provision or receipt of goods and services, and to make payments to you for services provided, the reimbursement of expenses or rebates, and managing orders, questions and complaints regarding products where you have placed orders, posed questions in relation to orders, or submitted complaints.
In some cases, we may also rely on the legitimate basis for compliance with a legal obligation such as trade sanctions or anti-bribery laws.
4. How long do we hold it?
The retention period for your personal data will depend on the activity. As stated above, generally we will keep contract and financial information for up to 11 years. In addition, we will keep:
|
Type of Personal Data |
Retention Period |
| GxP training | Up to 6 years |
| Technical support when accessing our Sites | Up to 4 years |
| Medical information and educational grants | Up to 7 years |
| Interactions through trade associations with other pharmaceutical companies | Up to 7 years |
| Product Samples | Up to 6 years |
| Investigation and Audit | Up to 8 years |
| Promotional Materials | Up to 7 years |
| Investigator Initiated Studies | Active + 25 years |
| Events and Exhibitions | Up to 4 years |