Our commitment to privacy
This website (<https://www.ocutears.co.uk/>) ( ,”website” or “service”) is operated by Santen UK Limited (Salisbury Hall, St Albans, AL2 1BU, UK, URL: https://www.santen.uk/) (“Santen”) to offer to our website visitors (“you”, “your” or “website users”) general information about eye conditions, over the counter treatments for dry eye disease as well as direct access to our products. You may also use our website to purchase our eyecare products such as Cationorm®.
At Santen, we recognize the importance of, and are fully committed to protecting the privacy of personal data related to all individuals with whom we interact – including patients, members of the public, healthcare professionals and business partners.
Individuals are recommended to read carefully this Policy before disclosing any personal data through any communications with Santen to request clarifications and/or more information relating to the available educational material published through this website. By visiting our website or by providing us your personal data, you agree and consent to the collection, use and disclosure of your personal information as outlined in this Policy.
Scope of this policy
This Policy is specifically intended to provide information to our website users, members of the public who interact with Santen, and patients that use Santen products.
Personal data we collect
We may collect and process the following personal data about you, including but not limited to:
- General identification data and contact details, such as name, postal and/or email address, phone number, when you subscribe to our website and create your personal account, when you subscribe to our newsletter for receiving the latest news for our products, when you make a purchase and/or when you submit a query to Santen after visiting/using our website;
- Professional data, such as your business address, business email address, business phone numbers, job title/position following any communications that you might have with us where you express your interest in Santen’s activities ;
- Digital data generated from your use of our website, such as IP address, your browser type and version, time zone setting, time period of user’s staying on a single page, the internal path analysis and/or other parameters regarding the user’s operating system and computer environment, browser plug-in types and versions, operating system and platform and other data transmitted via cookies. This data is collected and used only in an aggregated and not immediately identifiable manner; they could be used among others to ascertain responsibility in case of hypothetical crimes against the site or upon public authorities’ request.
Ways of obtaining personal data
When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary for us to provide your with additional services , we may not be able to provide you such information.
Purpose of processing personal data
Santen will collect, store, and otherwise process your personal data to provide general information about dry eye disease, over the counter treatments for dry eye disease as well as direct access to and online purchase of our products or for purposes permitted by applicable laws, including the UK Data Protection Act 2018 (DPA 2018), as amended and in force, and on the terms set forth in this Policy. By registering for and using this website you give your express permission to Santen to process your personal data for the purpose of delivering products and services to you and for other compatible purposes as further described below:
- Managing our relationships/communications with individuals: for example, responding to questions and comments or inquiries about our online educational material.
- Website functions: analysing your use of our website and gathering feedback to ensure that content from our website is presented in the most effective manner for you and for your device.
- Providing and managing your User/ Customer Account.
- Providing and managing your subscription and access to our website.
- Personalizing and tailoring your experience on our website.
- Supplying our products and services to you.
- Personalizing and tailoring our products and services for you;
- Supplying you with printed or email newsletters, promotions, alerts, product launches, competitions, offers and other updates related to products and serviced on our website (you may unsubscribe or opt-out at any time by clicking the unsubscribe link at the bottom of any email you receive or by contacting us);
- Market research;
Santen will process personal data for further purposes, where lawful to do so or when legally obliged to do so.
Legal basis of processing
Santen processes personal data based on one or more of the following conditions:
- Where you have provided your consent (in which cases, such consent can be withdrawn at any time and without giving any reason);
- Where processing is necessary for compliance with a legal obligation to which we are subject (e.g to comply with our quality and safety obligations);
- Where it is necessary to comply with our contractual obligations towards you; or
- Where we can rely on our overriding legitimate interests.
Redirect to other web sites
Place of data processing and ways of transmission
Santen UK Limited is located in England. Santen also operates through affiliates in Japan and other countries around the world. Personal data about you may be accessible to Santen EMEA affiliates as well as, to the extent permitted by applicable data protection law, to Santen affiliates outside European Union (“EU”)/European Economic Area (“EEA”), and to selected vendors and partners, established in the UK, EU/EEA or globally.
Where Santen processes personal information in countries that may not provide the same level of data protection as in the in UK, Santen will implement reasonable and appropriate legal, technical and organisational security measures with the aim to ensure the security of the processing and in particular to protect your personal data from unauthorised access, use or disclosure.
In the absence of an adequacy decision, Santen will implement appropriate data transfer mechanisms (such as the EU and/or UK Standard Contractual Clauses (SCCs)) or any other officially approved data transfer mechanism, for any cross-border data transfers from the UK to an affiliate or a third party (controller or processor) located in a third country outside of the UK and/or outside of the EU/EEA with the aim to secure such transfers and achieve an adequate level of data protection.
Contractual arrangements with third parties and international data transfers
As a data controller, Santen aims to establish a high level of data protection and privacy for its data subjects and partners alike. To that end, Santen has developed and uses specific privacy and security related language in its contractual arrangements with third party service providers acting for the benefit of Santen as data processors in compliance with applicable data protection legislation.
Through its privacy-compliant contractual arrangements, Santen sets out the scope, subject-matter, duration and purpose of the data processing activities carried out by its data processors and their sub-processors (if any) as well as the types of personal data processed and the involved categories of data subjects. Moreover, details are provided with regard to the service provider’s obligations in its role as data processor which include indicatively its confidentiality obligations, the procedure to be followed in case of a data breach incident, cooperation regarding inquiries from data subjects and authorities, assistance for the performance of data protection impact assessments, international data transfer mechanisms to be executed in the case of cross border data transfers, specific rules for the due diligence and engagement of sub-processors, implementation of appropriate security measures and personal data breach indemnification commitments.
Our service providers are required to be transparent and inform us in advance about their affiliates and any external collaborators (acting as sub processors) that might be involved in processing activities. In case that a service provider and/or any of its collaborators, are located outside the UK, we request where necessary that they also execute appropriate data transfer mechanisms with such third parties to cover any onward transfers; in particular the EU Standard Contractual Clauses (SCCs) or other approved transfer mechanism, in the absence of an adequacy decision and/or any other data protection related certifications implemented by such third parties. This approach establishes and maintains a high level of data protection and privacy for the individuals we interact with in the UK and beyond.
Disclosure of personal data
Personal data are not disseminated to unspecified recipients. Santen discloses your personal data to third party recipients on a need to know basis where this is reasonably permitted to pursue its legitimate business aims and as required by applicable law. Your personal data will be disclosed only in accordance with applicable laws, and appropriate safeguards through contractual agreements, will be established to protect your personal data.
We may disclose your personal data to third parties with which we have a contractual relationship in order to supply products and services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party as set forth under the law.
We have currently engaged directly or indirectly the following third parties to provide us with related services: Butterflies Healthcare Ltd, Royal Mail, Pick Pack Dispatch, APC, Google, MailChimp, Inland UK, PayPal, Stripe, Inc.
For more detailed information of these data processors and for a copy of the relevant data safeguards, you can email the Santen EMEA Privacy Office at firstname.lastname@example.org.
Security and data retention
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy, applicable data protection laws and regulations as well as international security standards. All data you provide to us is stored on secure servers and accessed and used subject to our security policies and standards. Santen has implemented reasonable physical, technical and managerial controls and safeguards to keep your personal data protected from unauthorised access, disclosure, alteration, and destruction. Such measures may include, but are not limited to: firewalls, access controls, encryption of information while it is in storage, separation of duties, and similar security protocols. To secure and protect your data we also make use of PCI compliant third parties for payment processing, site wide SSL encryption, fully maintained server hosting, and physical security. Access to your personal data is limited to a restricted number of Santen employees whose duties reasonably require such information and third parties with whom Santen contracts to carry out business activities on its behalf. Our employees have been trained on the importance of privacy and how to handle and manage personal information appropriately and securely.
We will retain your personal data for the time strictly necessary to achieve the purposes for which the data were collected and any other permitted associated purpose. Indicatively, for billing and accounting purposes we will retain financial details as well as order details for 6 years after the end of the financial year.
For promotional and email marketing purposes we may store your personal data until a request to remove is received or a maximum of 3 years after an email address becomes inactive.
Data may be retained for a longer duration where applicable laws or regulations require or allow Santen to do so. When your data is no longer needed it will be either irreversibly anonymised (and the anonymised information may be retained) or securely destroyed.
Automated decision making
Automated decision making as part of this website is limited solely to managing your profile preferences and other provided details from you to facilitate your access to the website and thus to our products and services. We will also analyse your use of the platform to tailor its contents to your interests and preferences and send you email notifications with related contents and updates subject to your express permission.
You have the right to object to such automated decision making by contacting us at email@example.com at any time.
Subscription to our website and our newsletter
On our website, you may subscribe to create a personal account in order to place your personal orders for our products, keep track of your orders or to design your new habits and work them into your daily routine with ease. Based on your prior consent, we will collect and use the email address you indicate for providing you with the newsletter
In addition, on our website, you may subscribe to receive our newsletter to get the latest news, blogs & offers. Based on your prior consent, we will collect and use the email address you indicate for providing you with the newsletter.
You may at any time evoke your consent to receive our newsletter.
After you have subscribed to the newsletter on our website your subscription will be automatically activated.
In order to prevent any misuse of your personal data, we will log your subscription and confirmation, filing the IP address you use when subscribing, the time of your subscription and confirmation, the messages sent by us regarding your subscription, and the wording of your subscription and confirmation.
To declare that you wish to unsubscribe either from our website and/or our newsletter, please send an e-mail to: firstname.lastname@example.org or using the contact details as referred below (at Your data protection rights & Contact information).
Your data protection rights
Under applicable laws and subject to any legal restrictions, you may have the right to request us to:
- Provide you with further details on the processing of your personal information;
- Provide you access to your personal data that we hold about you;
- Update any inaccuracies in the personal information we hold that is demonstrated to be inaccurate or incomplete;
- Delete any personal information that we no longer have a lawful basis to use;
- Provide you or a third party, with a copy of your data in a digital format (data portability);
- Stop a particular processing when you withdraw your consent;
- Object to any processing based on the legitimate interests or public interest to process information, unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
- Restrict certain aspects of the processing of your information.
All data protection related requests should be addressed to Santen privacy EMEA office at email@example.com.
If we do not handle your request in a timely manner, or if you are not satisfied with our response to any exercise of these rights, you are entitled to lodge a complaint with the competent supervisory authority. Further information and contact details of the UK competent supervisory authority (Information Commissioner’s Office) can be found here.
Santen reserves the right to amend this Policy from time to time to reflect technological advancements, legal and regulatory changes, and Santen’s business practices, subject to applicable laws. If Santen changes its privacy practices, an updated version of this Policy will reflect those changes by posting any revisions on with the respective update of the effective date listed on the bottom of this Policy. We therefore encourage you to periodically visit this page to stay informed of how we are using your personal data.
If you have any questions in relation to this Policy, or you want to obtain more information about Santen’s privacy practices, please contact our Santen privacy EMEA office by email at firstname.lastname@example.org.
Last updated: August 11th 2023