Veeva and Privacy Shield
Veeva and Privacy
Veeva Systems Inc.
EU-U.S. and Swiss-U.S. Privacy Shield Notice
Effective Date: April 12, 2017
Types of personal data collected
We collect business contact information from customers, suppliers and other business partners in the EEA (“EEA Business Contacts”), including name, job title, company affiliation and contact information. From EEA Site, visitors who request additional information about our products or who wish to access secure areas of our site, we collect name, company name, email address, mailing address, phone number, portal login ID, and password.
We also store and process personal data on behalf of our corporate customers. Our corporate customers use our cloud-based software products to process personal data at their discretion, including data pertaining to their own customers, employees, and patients.
We may obtain business contact information of health care professionals from third party public sources such as medical associations and directories.
We subject to the Principles all personal data that we receive from companies or individuals in the EEA (“EEA Data”) in reliance on the Privacy Shield. We also receive some data in reliance on other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses.
Purposes of collection and use
We collect and use personal data of EEA Site Visitors for purposes of providing products and services to our customers, communicating with corporate business partners about business matters, processing data on behalf of corporate customers, providing information on our services, and conducting related tasks for legitimate business purposes. With respect to marketing, data subjects in the EEA may opt-out of receiving marketing communications from Veeva or onward transfers of their data to other data controllers by following opt-out instructions that are contained in each marketing email or by contacting email@example.com.
How to contact us
If you have any questions regarding this notice or if you need to update, change or remove personal data that we control, you can do so by contacting firstname.lastname@example.org or by regular mail addressed to:
Veeva Systems Inc.
4280 Hacienda Drive
Pleasanton, CA 94588
To contact Veeva’s Global Data Protection Officer by regular mail:
Ashley Slavik, CIPP/E
131 Avenue Charles de Gaulle, Building A
Types of third parties to which we disclose personal data and purposes
Veeva is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Veeva Systems complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
We share EEA Data with our subsidiaries, affiliates and contractors, who process personal data on behalf of Veeva. We also provide information to our channel partners, such as distributors and resellers, to fulfill product and information requests, and to provide customers and prospective customers with information about Veeva and its products and services. We also share EEA Data with other third parties for the purposes for which we receive the EEA Data (e.g., performance of contractual obligations and rights), and we may also disclose EEA Data where we are legally required to disclose (e.g., under statutes, contracts or otherwise) or where the disclosure is permitted by law or the Privacy Shield Principles and we have a legitimate business interest in such disclosure.
EEA Site Visitors may opt out of disclosures to entities other than agents unless the disclosure is required by law or necessary under contracts by sending an email to email@example.com, but such an opt-out request may make it difficult or impossible for us to provide requested services. We try to minimize disclosures of personal data as reasonably practical because we are mindful of our responsibility and potential liability in cases of onward transfers to third parties.
Right to access
EEA Site Visitors have the right to access personal data about them. Upon request, we will provide you with information about whether we hold any of your personal information. To access your personal data, contact firstname.lastname@example.org.
Because Veeva may have limited ability to access data our customers submit to our services, if you wish to request access, limit use or disclosure, please provide the name of the Veeva customer who submitted your data to our services. We will refer your request to that customer, and will support them as needed in responding to your request.
Choices and means
EEA Business Contacts may choose to change personal data, unsubscribe from email lists, or cancel an account by contacting email@example.com. EEA Site Visitors may choose to unsubscribe from our marketing communications by following the instructions or unsubscribe mechanism in the email message.
Independent dispute resolution body
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Investigatory and enforcement powers of the FTC
Veeva’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Requirement to disclose
Veeva may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Under the Swiss-U.S. Privacy Shield, Veeva satisfies points (a)(i) and (a)(iii) of the Recourse, Enforcement and Liability Principle by committing to cooperate with the Swiss Federal Data Protection and Information Commissioner. When covering employee data received from Switzerland for use in the context of the employment relationship, Veeva commits to cooperate with and comply with the advice of the Commissioner.
Personal data may be compliantly transferred from the United Kingdom (the “UK”) under the Privacy Shield pending the UK’s formal withdrawal from the European Union and the UK’s adoption of legislation amending or superseding the UK Data Protection Act 1998. The conditions applicable to the transfers from the UK will need to be re-assessed following the UK’s official exit from the EU.