MyVaccinationHub Privacy Policy

Dear User,

Welcome to MyVaccinationHub, a service provided by GSK (or We) by which you can have at hand, an electronic record of the vaccination process of your kids, and information related to vaccines for informative purposes, exclusively, which cannot replace or cannot be treated as professional advice in any regard. MyVaccinationHub is a service intended for the parents, and consequently, for adults. GSK doesn’t expect or want MyVaccinationHub to be used directly by kids or adolescents. 

As part of making the service available and useful GSK may collect some personal information related to you, as the account user of MyVaccinationHub records, and your kids. Please note, that GSK is committed to protecting your privacy. This Privacy Policy explains what information will be collected by GSK, how we process, collect and use the personal information relating to you and your kids, registered in MyVaccinationHub and the rights you have regarding this Privacy Policy. We will not use or share your information with anyone except as described in this Privacy Policy.

 

1.      What personal information do we collect/process about you?

To create your account as user of MyVaccinationHub, we will process the following information about you:

(i) your basic information – such as name; and,

(ii) your email address;

This information is necessary to create the account and have access to MyVaccinationHub platform from now and on.

When you use MyVaccinationHub, we will also process information generated or registered/uploaded by you, such as:

(i) your username and password;

(ii) technical data such as: (a) information about the device you use to get access into MyVaccinationHub (including the unique device identifier, hardware model, operating system and version, and mobile network information), and (b) information from your visits to MyVaccinationHub (including the type of browser and operating system you use, access times, pages viewed, URLs clicked on, your IP address); (c) information and metadata in or about the content you provide, such as the location (geolocation) or the date a record was created. 

(iii) your email address and/or your mobile number, only if you want to get access to the contextualized reminder service.

If you decide to use MyVaccinationHub to create a personalized vaccination calendar for your kid(s), we may also process:

(i) your kid(s)’ name.

(ii) Information related to the vaccines received by your kids, as registered by you.

(iii) gender and date of birth of your kid(s)

(iv) your kid(s)’ picture; just if you decided to upload a picture to identify the records.

Please note that GSK does not require specific details, or identify by name or by any other information, your kids in order that you can record the vaccines that they have received. It means that you are free to record the vaccines using the real name or a nickname or any other identifier that helps you to keep the records. We prefer and recommend using a nickname, instead of the name, or an avatar instead of a real picture, to identify the records of your kids.

 

It is completely up to you to modify your user profile or upload/register additional personal information on MyVaccinationHub, including the vaccines records. You can always choose not to share your personal information or ask for deletion. In case you want to do it, please refer to “your rights” and “contact” sections of this privacy notice.

2.      How do we obtain your personal information?

We collect your personal information when you provide it to us, for example, when you ask for having an account for accessing MyVaccinationHub service or when you use the MyVaccinationHub.

3.      How do we use your personal information?

We use your personal information to operate, maintain and provide to you the features and functionality of the service, such as the following purposes:

(i) creating your MyVaccinationHub account;

(ii) creating a personalized vaccination calendar for your kid(s);

(iii) storing the data uploaded when using MyVaccinationHub;

(iv) to gather statistical data, analytics, trends and other high-level aggregated data derived from your use of MyVaccinationHub in a form that does not directly or indirectly identify you or your kids;

(v) complying with legal obligations;

(vi) monitoring your use of MyVaccinationHub to ensure compliance with GSK policies and applicable law;

(vii) transferring and sharing your personal information on the terms established on this Privacy Notice; and

(viii) creating and maintaining backups.

(ix) Providing and sending over to you contextualized reminders about upcoming vaccination recommended in the national vaccination schedule for your child(ren)

 

4.      On what basis do we use your personal information?

GSK uses your personal information on the following basis:

(i)  For granting you access to MyVaccinationHub service.

(ii)  For the processing of especial categories of information such as the one related to the vaccination records, or a real profile picture or information of your kids, or for the processing of technical data, such as cookies or geolocation, we rely on your consent. You always can revoke your consent at any time.

(iii) for the legitimate interests of GSK, such as to help GSK operate and improve MyVaccinationHub with more relevant and personalized content to you; and

(iv) to comply with certain legal and regulatory obligations of GSK;

 

5.      Data handling

GSK applies technical and organizational measures to protect the security of the personal information that you trusted us and to prevent any accidental lost, use, access by non-authorized parties, alteration or disclosure. GSK has in place procedures to respond to a data breach, and to notify you and any applicable regulator or authority where legally required.

GSK reserves the right, but has no obligation, to monitor the information that the User includes in the Service. We reserve the right to remove any such information or material for any reason or no reason, including without limitation if in our sole opinion such information or material violates, or may violate, any applicable law or our Terms of Use Agreement, or to protect or defend our rights or property or those of any third party. GSK also reserves the right to remove information upon the request of any third party.

6.      How long will we keep your personal information?

We will keep your personal information if required to fulfil the purposes described above.

If you decide to delete your account in MyVaccinationHub, we will delete your information if there is no legal duty that obligates us to retain all or part of your information.

We will also keep your personal information where we need to do so in connection with legal action or an investigation involving GSK.

7.      With whom do we share your personal information?

We share your personal information with: (i) members of GSK group; and (ii) the following third parties, which, in some of the cases help us to have the technological infrastructure to provide the service, or to comply with our internal procedures and obligations: (a) Amazon Web Services, Inc., which is our data centre provider and  also acts as email and sms provider; (b) Gigya, Inc. which is our customer identity and access management provider; (c)GSK contracted suppliers of related services such as data retention and system suppliers; (d) our professional advisors and auditors. If we do this, such third parties’ use of your information will be bound by this Privacy Policy.

Except as otherwise described in this Privacy Policy, GSK will not disclose personal information to any third party unless required to do so by law or if we believe that such action is necessary to (a) conform to the law, comply with legal process served on us or our affiliates, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Use, take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, or to protect the security or integrity of our site; and (c) to exercise or protect the rights, property, or personal safety of GSK, our Users or others.

8.      Transfers of your personal information outside of your home country

Your personal information may be processed by the parties described above, anywhere in the world, including countries such as India and United States. We will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred.

Amazon Web Services, Inc. and  Gigya, Inc. have certified to the EU-US and Swiss-U.S. Privacy Shield Frameworks. Under the EU-US and Swiss-U.S. Privacy Shield Frameworks (as amended from time to time) (“Privacy Shield”) Amazon Web Services, Inc. and Gigya, Inc. have made commitments in respect of the data received from GSK users. More information on Amazon Web Services, Inc. and Gigya, Inc.’s participation in Privacy Shield is available here: https://www.privacyshield.gov

9.      Protecting your personal information

We use a variety of security measures and technologies to help protect your personal information from unauthorized access, use, disclosure, alteration or destruction consistent with applicable data protection and privacy laws. We also manage content and personal information with confidentiality controls appropriate to the context, in accordance with local laws, and after appropriate consultation.

To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from GSK, at all time.

10.   Your rights

You may update your MyVaccinationHub profile information and content online and may be entitled to: (i) ask GSK about the processing of your personal information, including to be provided with a copy of your personal information; (ii)request the correction and/or deletion of your personal information - Some information may remain in backup copies for a reasonable period of time, after that, the information will be permanently deleted from our databases, as requested; (iii) request the restriction of the processing of your personal information, or object to that processing; (iv) request receipt or transmission to another organization, in a machine-readable form, of the personal information that you have provided to GSK; and (v) complain to your local supervisory authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal information.

You are given the option to share additional personal information with us, and you can always choose not to do so. If you object to the processing of your personal information, we will respect that choice in accordance with our legal obligations. This could mean that you are unable to use MyVaccinationHub.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

 

This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described (see ‘How do we use your personal information?’) or that you are unable to make use of MyVaccinationHub. After you have chosen to withdraw your consent GSK may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with our obligations.

For revoking your consent, you may contact us or delete your account through the website.

If you would like to exercise any other right, please let us know by getting in touch.

11.   Data Incident

In case of any personal information is compromised as a result of a breach of security, GSK will promptly notify the relevant government agencies and those individuals whose personal information has been compromised, in accordance with the  applicable law.

12.   Data controller

GlaxoSmithKline Biologicals S.A, Rue de l’Institut 89, 1330 Rixensart, Belgium, is the controller of your personal information on MyVaccinationHub. You can contact our data protection officer at eu.dpo@gsk.com

13.   Changes to this Privacy Notice

GSK may update this Privacy Notice at any time. In case we do so, we will provide you with a new or updated Privacy Notice on the website of MyVaccinationHub.

14.   Contact Us

If you have questions or requests about the processing of your personal information, please get in touch with:

Privacy grievance officer | India LOC

Gaurav Gupta
GlaxoSmithKline Pharmaceuticals Limited
Email: in.privacy@gsk.com