General Guidelines for social media
Due to the remarkable development of social media in recent years, we begin social media activities to further improve Santen's corporate and brand value. When engaging with our social media accounts, please take into consideration and follow the simple rules below, and make sure you check back from time to time because these may change without prior notice to Users.
We encourage you to interact with Santen by following us. However, please note that the information contained in our social media accounts is solely for information purposes and should not be viewed as professional or medical advice. Always seek the advice of your physician or other qualified health care provider with any questions you may have regarding a medical condition. Reliance on any information provided herein is solely at your own risk.
Users are prohibited from posting content (e.g. when you reply to or mention @Santen) or otherwise on Santen’s social media accounts in a manner that may fall into the categories described below. If and when such prohibited acts and/or posts are confirmed, such posted content will be deleted and/or the account will be blocked without prior notice by Santen; we also reserve the right to take legal action as deemed necessary.
1. Posts that conflict with, violate or may conflict with or violate, any law or regulation.
2. Posts that contain information with misleading, incorrect, fraudulent or deceptive content, or that includes defamatory, libelous and/or offensive or demeaning language (including images, videos and links).
3. Posts that violate public order and/or morals.
4. Posts that make reference to a medicinal product/medical device or a possible side effect/incident (see ‘Posting Adverse Events or Incidents’ for more information).
5. Posts of medical advice or medical commentary by physicians or posting which aims to recommend, request or increase referrals to physicians.
6. Posts that promote medicinal product(s) or medical device(s).
7. Posts that contain any content that constitutes personal health information including patient images.
8. Posts of topics related to criminal acts or that may constitute criminal acts.
9. Posts relating to religious activities, inducement activities to religious group, and/or any other activities similar thereto.
10. Posts relating to political activities, inducement activities to political organisation, and/or any other activities similar thereto.
11. Posts that have a purpose of meeting unacquainted persons.
12. Posts that encourage, imply, and/or induce any form of abuse, violence, illegal action, etc.
13. Posts of information related to any websites or businesses that might contain inappropriate or obscene information including but not limited to documents, images, videos etc., and/or encouraging other Users to visit websites containing any such content.
14. Posts that contain proprietary, confidential, sensitive or non-public information about, or related to, Santen or any other person.
15. Posts that disclose any information such as contact details of one's own or of person(s) that enables to identify individuals and makes it easy to contact them.
16. Posts made by fake Users.
17. Posts that contain inappropriate comments or inferences about Santen and/or Santen’s competitors.
18. Posts that solicit business, or request donations.
19. Posts that are spam, or otherwise automatically generated content, directed at Santen or Santen's followers.
20. Posts that are excessively repetitive and/or disruptive to the community.
21. Posts that contain information about minors.
22. Posts containing disrespectful comments for other members of our social media communities.
23. Acts or posts that discriminate, slander, and/or threaten people, or acts that damage the reputation and/or trust of any person(s).
24. Acts or posts that damage or may damage the trust of Santen and/or Santen’s social media accounts.
25. Infringement acts on the copyright, trademark right, and/or other intellectual property right of any person(s).
26. Infringement acts on the privacy right, portrait right, and/or other rights of any person(s).
27. Acts that obstruct the operation of Santen’s social media accounts.
28. Acts of using Santen’s social media accounts for commercial purposes without our prior written permission.
29. Acts that allow transmission of information including computer viruses and/or other harmful computer programs.
30. Acts that enable unauthorized access to Santen’s social media accounts and/or the company's facilities (including Administrative computer).
Posting Adverse Events or Incidents
Our social media accounts are not intended for the reporting of adverse events related to the use of Santen (or any other company) medicinal products or incidents related to the use of Santen (any other company) medical devices. To report an adverse event/incident or other safety finding related to a Santen medicinal product/medical device, please contact the appropriate health authorities in your country or the corresponding Santen Office responsible for medical information and adverse event reporting through the designated channels (https://www.santen.eu/contact/feedback-on-products).
We inform you that all personal data that you may provide through a post or a direct message to our social media accounts will be collected and used by Santen and its Affiliates in accordance with our relevant privacy notice for medical information, safety vigilance and product quality complaints, available on our corporate website here: https://www.santen.eu/data-privacy/handling-of-medical-information.
Consent to Processing
If you wish to learn more about Santen’s news and activities, you can choose to “follow” or “like” one of our social media accounts. This will result in your ability to see Santen’s posts displaying its news through your News feed; alternatively, you can select to search and visit on your own initiative any of our individual social media accounts publicly available on the social media platforms. If you change your mind, you can stop following us by un-choosing “following” or pressing “unlike”. When you follow or like Santen’s social media accounts you allow Santen and the respective social media owner to access your social media account and profile information (e.g. User's basic information that are open; open profile information such as User name; profile picture; gender; network; User ID; friends list; etc.): both Santen and the respective social media owner will be autonomously processing your personal data/personal information as data controllers. For any and all data collected automatically and further processed by the social media owner, the latter will be solely responsible as data controller towards you and your data. For any and all data collected and further processed by Santen, the latter will be responsible as data controller.
Santen’s social media Accounts, are public: all posts are non-confidential. When you repost or reply to or mention @Santen through your “likes” or ”tweets”, you consent to the fact that your name, “likes”, “tweets” and social media handle will be visible and associated with your post and that we (and any other social media User) may re-use your post elsewhere and thus, we (and any other social media User) may display your name, “likes”, “tweets” and handle there as well, for any other purpose.
Santen is using business advertising services provided by the social media platforms to deliver to target audiences promoted social media ads (e.g. promoted tweets; targeted Facebook ads) via its corporate promoted social media accounts. If you receive Santen promotional information through our social media accounts, it is because you are either one of our “followers” or you have otherwise provided your consent to the social media platforms to be receiving in general promotional information from other business social media accounts. In the latter case, check your marketing choices with the social media platforms to keep your marketing preferences up-to-date at any time or to opt-out from the specific social media ads altogether.
How to opt out from social media ads
The social media platforms adhere to the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising (also referred to as “interest-based advertising”) and provides their social media Users with the DAA’s consumer choice tool for you to opt out of such interest-based advertising by following the available link at https://optout.aboutads.info. For further information on each social media platform’s advertising services and practices read the respective privacy policies.
Queries & contact details
If you have any data protection related queries with regard to these terms or you wish to exercise any of your privacy related rights (e.g. access, rectification, erasure, restriction, portability, objection, withdrawal of consent/ opt-out of marketing activities) or you have any concerns on how Santen processes your personal data, please contact us by email at firstname.lastname@example.org; you may also contact us in writing at the postal address indicated in the beginning of these terms.
If you do not receive a (timely) response to your enquiry from us or you are not satisfied with our response, you can also submit a complaint to the competent data protection authority. A current list with the competent EU data protection authorities can be found at the following link: https://edpb.europa.eu/about-edpb/board/members_en.
We may occasionally share links to third-party owned websites if we think you will find the information helpful. However, please note that this does not in any way constitute any endorsement, official or otherwise, of such third-party websites or companies. We are not responsible for the terms and conditions, privacy policies, cookies statements and other policies and practices or content of any website accessed through links or references in our social media accounts. Santen shall only be responsible for the protection of the personal data that is provided by the User through Santen’s social media accounts and does not take any responsibility for the treatment and subsequent use of such personal data that could be carried out by the social media platform themselves or by third party content providers, which could access such data for the purpose of providing their services they establish hyperlinks to third party owned social media accounts.
Third-party Service Providers
Santen also engages third parties providers for technical support, maintenance and monitoring services in relation to its social media accounts; in such case Santen ensures that such data processors, when acting on its behalf, comply with applicable laws and regulations and internal Company policies on data protection by entering into binding data processing agreements with them to ensure an adequate level of data protection and the security of processing. Where such engagement involves also the transfer of personal data to third countries (outside the EU/EEA), appropriate data safeguards are implemented by executing appropriate standard contractual clauses applicable for cross-border data transfers as adopted by the European Commission and/or competent supervisory authorities.
The User retains the copyright and so forth of the posted contents and any ideas or techniques contained in them, to the Company's social media accounts ; however, by such posting (including reply to or mention @Santen), the User will grant to the Company a worldwide and non-exclusive right to use (copy, process, translate, extract, publish, etc.) in any way and in any media, including on our corporate website and our other social media channels, and within our business, all or part of the contents without prior consents from the User and without royalty payment. In addition, the User will be deemed as agreeing not to enforce copyright, moral rights of author and so forth against the Company. Accordingly, please do not submit any ideas or materials that you wish to keep confidential.
1. Because our social media accounts are public and anyone can engage with us, we cannot be responsible for views expressed other than our own. The Company does not provide any warranties including the accuracy, integrity, truth, legality, purposiveness of the contents such as comments posted by Users. Santen does not verify, represent or endorse any opinions or information expressed by third-party organizations or individuals posting content to the Santen social media accounts. Santen has no responsibility for actions made by the Users and/or any content posted by anyone other than Santen. Comments and other material not posted by Santen do not necessarily reflect Santen’s views or opinions. Furthermore, the Company shall not be responsible for any damages to Users and/or third parties caused by the use of such information.
2. The User warrants that all content posted by the User such as data, texts, images, videos, etc. do not infringe any rights including the intellectual property right, privacy right, publicity right, and honorary right of any third party. The Company shall not be responsible for any damages to other Users and/or third parties, or any infringements and/or conflicts caused by the use of such posted data.
3. The Company reserves all rights related to its social media accounts and may at its sole discretion and without prior notice, add, remove or modify any content or material posted on such accounts, discontinue, suspend or terminate the operation of such accounts, except or reject those who may wish to “follow” or “like” the accounts. We shall not be responsible for any damages caused by changes or additions in the contents of the Company's social media accounts, or by the suspension or termination of its operation.
4. We shall not be responsible for any damages caused by: i) troubles arising among Users or between a User and any third party related to our social media accounts; ii) harmful programs such as computer viruses and/or malwares.
Governing Law and Venue
These terms shall be interpreted and applied in accordance with Swiss law. Any disputes arising as a result of these terms or in relation to the use of Santen’s social media Accounts shall be adjudicated before the competent courts of Geneva, Switzerland.
Santen social media Official Accounts
Santen maintains a number of official social media accounts as a new vehicle for communicating updates and information with the general public about Santen activities and healthcare related issues.
Last updated: 02/02/2021