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Privacy Policy

I. INTRODUCTION

Sun Pharmaceutical Industries Limited (“Sun Pharma“, “we“, “our“, or “us“) respects the privacy of individuals and is committed to protecting your personal data and respecting your privacy. This Privacy Policy details our practices concerning the collection, use, disclosure, and protection of your personal data when you interact with our services, products, and digital platforms. We take reasonable precautions to protect your Personal Information and Sensitive Personal Data or Information (“SPDI”) (together referred to as “Information”) and comply with all legal, regulatory, and contractual obligations related to data privacy.

This Privacy Policy has been enhanced to incorporate best practices from ISO-certified pharmaceutical companies and ensure compliance with the Information Technology Act, 2000 – Section 43A, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and other applicable laws.

II. DEFINITIONS

For the purposes of this Privacy Policy, the following terms shall have the meanings as defined in applicable laws:

  • “Body Corporate” means any company and includes a firm, sole proprietorship or other association of individuals engaged in commercial or professional activities as defined under the Information Technology Act, 2000
  • “Personal Data” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.
  • “Sensitive Personal Data or Information” means such personal information which consists of information relating to passwords, financial information, health condition, sexual orientation, medical records and history, and biometric information.
  • “Biometrics” means the technologies that measure and analyze human body characteristics, such as fingerprints, eye retinas and irises, voice patterns, facial patterns, hand measurements, and DNA for authentication purposes.
  • “Provider of information” means persons who provide sensitive personal data or information to a body corporate.

III. SCOPE AND APPLICABILITY

This Policy applies to all personal information and Sensitive Personal Data or Information (in short, ‘SDPI’) collected and processed by Sun Pharma through:

  • Our website(s), mobile application(s) or any other digital platform
  • Communication(s) with Sun Pharma representatives
  • Business relationship(s) with Sun Pharma
  • Our offline interactions with customers and business partners
  • Participation in events, conferences, and other professional settings

By accessing our website(s), mobile application(s) or any other digital platform and/or providing your Information to Sun Pharma, you consent to the terms of this Privacy Policy and the processing of your Information as described herein.

IV. INFORMATION WE COLLECT

SPDI collected, received, stored, transmitted, or processed by Sun Pharma may include:

  • Passwords
  • Financial information such as bank account or credit card or debit card or other payment instrument details
  • Physical, physiological, and mental health condition
  • Sexual orientation
  • Medical records and history
  • Biometric information
  • Any detail relating to the above categories as provided to Sun Pharma for providing service

Personal information which may be collected includes:

  • Identity Data such as Full name, personal contact numbers, residential address, email address, gender, date of birth.
  • Technical Data such as Internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
  • Usage Data such as Information about how you use our website(s), mobile application(s) or any other digital platform, products, and services.
  • Marketing and communications data such as your preferences for receiving marketing and communications from us.
  • Audio, electronic, visual information such as recordings from video conferences or calls.
  • Geolocation data such as precise location data from mobile devices or applications.

For healthcare professionals, we may also collect:

  • Professional role(s) and qualifications
  • Specialty and employer information
  • Professional experience and publications
  • Information about prescribing practices (aggregated and de-identified)
  • Other profession-related information

Please note that any information freely available or accessible in the public domain or furnished under the Right to Information Act, 2005, or any other law for the time being in force shall not be regarded as SPDI.

V. HOW WE COLLECT INFORMATION

We collect Information through various methods:

  • Direct interactions when you provide information voluntarily through forms, registrations, surveys, or correspondence
  • Automated technologies or interactions through cookies, server logs, web beacons, pixels, and similar technologies
  • Third-party sources including public databases, providers of demographic information, joint marketing partners, professional organizations, social media platforms, and other third parties.
  • Through our interactions at events, conferences, and other professional settings

VI. PURPOSES FOR INFORMATION COLLECTION AND PROCESSING

Sun Pharma collects and uses Information for legitimate business purposes, including but not limited to:

  • To enable visitors of our website(s), mobile application(s) or any other digital platform to download information, products, and take advantage of features on our website.
  • To provide information or interactive services through our website(s), mobile application(s) or any other digital platform.
  • To seek feedback or contact visitors regarding services offered on our website.
  • To process orders or applications submitted by visitors.
  • To administer or carry out obligations in relation to any agreement with Sun Pharma.
  • To anticipate and resolve problems with goods or services supplied.
  • To create products or services that may meet visitors’ needs.
  • To process and respond to requests, improve operations, and communicate about products, services, and businesses.
  • To comply with regulatory, tax, and pharmacovigilance requirements.
  • To respond to government information requests.
  • To manage medical inquiries and quality-related matters.
  • To fulfill transparency and disclosure obligations.
  • To detect, investigate, and prevent fraudulent transactions and other illegal activities.
  • For responding to a medical emergency involving a threat to life or immediate threat to health.

Sun Pharma shall collect only minimum Information required to meet the purposes mentioned in this policy.

VII. LEGAL BASIS FOR PROCESSING

We process your personal information on the following legal bases:

  • Consent: We will seek your consent, which will be free, specific, informed, unconditional, and unambiguous, before processing your personal data, especially SPDI. We will provide a clear notice detailing the data collected, processing purpose, your rights, and how to file complaints, in appropriate languages. You have the right to withdraw consent easily, after which we will cease processing unless legally required.
  • Contract: Where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract
  • Legal Obligation: In specific situations defined by law, we may process personal data without consent, such as when you voluntarily provide data without indicating non-consent, for government services, compliance with legal obligations or court orders, medical emergencies, public health crises, or for employment purposes.
  • Vital Interests: Where processing is necessary to protect the vital interests of you or another natural person.
  • Legitimate Interests: Where processing is necessary for our legitimate interests or those of a third party, provided your fundamental rights and freedoms do not override those interests.

VIII. SPECIAL PROVISIONS REGARDING CONSENT

We adhere to the following principles regarding consent:

  • Consent shall be considered to be given by any lawful method including but not limited to checking a box, clicking on an “I agree” button, or signing a form.
  • You have the right to withdraw your consent at any time.
  • All requests for consent shall be presented in clear and plain language.

IX. COLLECTION NOTICE REQUIREMENTS

Sun Pharma shall not collect sensitive personal data or information unless:

  • The information is collected for a lawful purpose connected with a function or activity of Sun Pharma.
  • The collection of the sensitive personal data or information is considered necessary for that purpose.

Sun Pharma shall ensure that the person concerned is aware of:

  • The fact that the information is being collected.
  • The purpose for which the information is being collected.
  • The intended recipients of the information.
  • The name and address of the agency that is collecting the information and the agency that will retain the information.

Sun Pharma shall not retain SDPI for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force.

X. SPECIAL PROVISIONS FOR CHILDREN’S DATA

Sun Pharma shall:

  • Not knowingly collect personal information online from a child under the age of 13 without obtaining prior parental consent.
  • Obtain verifiable parental consent before processing any personal data of children.
  • Not undertake tracking or behavioral monitoring of children or targeted advertising directed at children.

XI. INFORMATION SECURITY

Sun Pharma has implemented and maintains appropriate technical, administrative, and physical safeguards to protect the security of your Information in accordance with the IS/ISO/IEC standards and/or the approved codes of best practices for data protection.

In accordance with the applicable rules and regulations, Sun Pharma has adopted the following reasonable security practices and procedures:

  • Documented information security program and policies that contain managerial, technical, operational, and physical security control measures commensurate with the information assets being protected.
  • Comprehensive security policies and procedures aligned with the IS/ISO/IEC standards and/or the approved codes of best practices for data protection on ‘Information Technology – Security Techniques – Information Security Management System – Requirements’.
  • Regular review and updates to our security measures to meet business needs, changes in technology, and regulatory requirements.
  • Encryption of sensitive information during transmission.
  • Access controls to limit access to Information on a need-to-know basis.
  • Security incident management procedures.
  • Regular security audits and assessments by an independent auditor at least once a year.
  • Employee training on data security and privacy.

In the event of a security incident, we will promptly investigate the matter to assess its impact. As required by law, we will report specific cyber security incidents to the Indian Computer Emergency Response Team (CERT-In) within the stipulated timelines.

Furthermore, in line with our commitment to transparency, it is our policy to notify affected individuals if we determine that a data breach is likely to cause them harm. This notification will describe the nature of the breach, the potential consequences, and the steps you can take to protect yourself.

Despite our efforts, no organization can guarantee the absolute security of information, especially information transmitted over the Internet. We are not responsible for the circumvention of any privacy settings or security measures on our website.

XII. INFORMATION SHARING AND DISCLOSURE

Sun Pharma shall not use or disclose Information for purposes other than those mentioned in this policy, except with your consent or as required by law. Sun Pharma may disclose SDPI without obtaining prior consent from the provider of information in the following circumstances:

  • When the disclosure is required to be made to government agencies mandated under the law to obtain information for the purpose of verification of identity, or for prevention, detection, investigation, prosecution, and punishment of offences
  • When the disclosure is made pursuant to a lawful contract between Sun Pharma and the provider of information
  • When the disclosure is necessary for compliance with a legal obligation

We may share your Information with:

  • Other Sun Pharma group companies for the purposes identified in this privacy notice.
  • Service providers and business partners who are contractually obliged to use the personal data according to our specifications.
  • Government authorities and regulatory agencies, if required by law.
  • Third parties in connection with a corporate transaction, such as a merger, acquisition, reorganization, or sale of assets

When sharing Information with business partners or third parties, Sun Pharma shall ensure that:

  • The Information is processed legitimately and appropriately in line with established consent or legal requirements.
  • The business partner or third party has adopted reasonable and equivalent security practices and procedures.
  • Appropriate contractual provisions are in place to ensure adequate protection of personal data.

Any third party that receives sensitive personal data or information from Sun Pharma shall not disclose it further.

XIII. INTERNATIONAL DATA TRANSFERS

The personal data we collect may be stored, accessed, or processed in countries where we maintain operations or employ service providers. When we transfer personal data internationally, we ensure appropriate safeguards are in place to protect your information and comply with applicable data protection laws.

Sun Pharma may transfer sensitive personal data or information to any other body corporate or a person in India, or located in any other country, that ensures the same level of data protection that is adhered to by Sun Pharma as provided for under the applicable Rules, only if such transfer is necessary for the performance of the lawful contract between Sun Pharma and provider of information or where such person has consented to data transfer.

XIV. COOKIES AND SIMILAR TECHNOLOGIES

Our website may use cookies and similar technologies to enhance user experience, analyze website usage, and personalize content. These technologies may collect information such as your IP address, browser type, operating system, referring URLs, device information, and browsing actions and patterns.

For more detailed information about the cookies we use, please see our separate Cookie Policy.

XV. TARGETED MARKETING

To communicate more effectively with individuals interested in our company, our non-prescription products, and general health awareness campaigns, we may engage in targeted marketing, sometimes referred to as interest-based advertising. This section describes how we conduct such marketing and how you can exercise control over your data.

Our Approach to Targeted Marketing:

Our targeted marketing practices are limited to our general audience websites and digital campaigns. We use information such as your general location and your browsing activity on our public websites to present you with advertisements that we believe may be more relevant to your interests.

We do not use SDPI for targeted marketing. Specifically, we do not use any information you provide through our secure programmes, portals, or any platform where your interaction could imply a specific health condition, for the purposes of targeted marketing or interest-based advertising.

Use of Third-Party Partners and Your Choices:

We work with third-party advertising partners, such as ad networks and social media platforms, to help deliver our marketing messages. These partners may use cookies, pixel tags, and other similar technologies to collect information about your online activities over time and across different websites to help us serve our advertisements.

You can opt-out of receiving interest-based advertising from many of our third-party partners by visiting the industry-led resources below:

  • Digital Advertising Alliance (DAA)
  • Network Advertising Initiative (NAI)
  • Or any entity of like nature

In addition to the industry opt-out tools, you can control your advertising preferences through the following methods:

  • You can modify your browser settings to block or delete cookies. Please be aware that if you block cookies, some functionalities on our websites may be limited.
  • You can use the privacy settings on your mobile device to limit the use of information about your app usage for targeted advertising.
  • Contacting us directly using the information in the “Contact Us” section.

 

Please note that opting out of targeted marketing does not mean you will no longer see our advertisements online. It simply means that the ads you do see will not be tailored to your inferred interests based on your past browsing activity.

XVI. YOUR RIGHTS

You have the following rights regarding your personal information:

  • Right to Access: The right to review or amend the information provided to Sun Pharma.
  • Right to Correction: The right to correct any inaccuracies in the information.
  • Right to Opt-Out: The right to opt-out of providing information at any point of time while availing services of Sun Pharma.
  • Right to Withdraw Consent: The right to withdraw consent at any time for processing based on consent.

Additionally, depending on your location and applicable laws, you may have the following additional rights:

  • Right to Erasure: The right to request deletion of your personal data in certain circumstances.
  • Right to Object: The right to oppose processing based on legitimate interests or for direct marketing.
  • Right to Restriction: The right to request restriction of processing in specific situations.
  • Right to Data Portability: The right to request transfer of your data to another organization in a structured, commonly used, and machine-readable format.

To exercise these rights, please contact us using the information provided in the “Contact Us” section

XVII. GRIEVANCE REDRESSAL MECHANISM

Sun Pharma has designated a Grievance Officer to address any discrepancies and grievances with respect to processing of information. The name and contact details of the Grievance Officer are provided in the “Contact Us” section. The Grievance Officer shall redress the grievances of the provider of information expeditiously but within one month from the date of receipt of grievance.

XVIII. RETENTION PERIOD

Sun Pharma shall not retain SDPI for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. The criteria used to determine our retention periods include the duration of our ongoing relationship with you, legal obligations to retain data for certain periods, relevant statutes of limitations and the period for which the personal data is required to serve the purpose for which it was collected. Once personal data is no longer necessary for the specified purpose, we will securely delete or anonymize it in accordance with our internal data retention policies.

XIX. CHANGES TO THIS PRIVACY POLICY

Sun Pharma shall publish this privacy policy on its website. This privacy policy shall include clear and easily accessible statements of our practices and policies. Sun Pharma may change this Privacy Policy from time to time. When we make material changes to this Privacy Policy, we will notify you by posting the updated policy on our website with a new effective date. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your Information.

XX. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: [email protected]
Phone: +91 4324 4324
Address: Sun House, Plot No. 201 B/1, Western Express Highway, Goregaon (E), Mumbai – 400063, Maharashtra, India

For grievances related to your personal data, please contact our Grievance Officer at:

Grievance Officer
Email: [email protected]
Phone: +91 4324 4324
Address: Sun House, Plot No. 201 B/1, Western Express Highway, Goregaon (E), Mumbai – 400063, Maharashtra, India

XXI. GOVERNING LAW

This Privacy Policy is governed by and interpreted in accordance with the laws of India, without regard to the choice or conflicts of law provisions of any jurisdiction. In the event of any dispute arising in relation to this Privacy Policy, the exclusive jurisdiction shall be with the courts located in Mumbai, India.

Last Updated: September, 2025

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