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Acceptance

Your access to and use of this Site is subject to the following terms and conditions and all applicable laws. By accessing and browsing this Site, you accept, without limitation or qualification, these Terms and Conditions and acknowledge that any other agreements regarding the use of this Site between you and Aspen Europe GmbH, UK branch, are superseded and of no force or effect.

About Us

emla.co.uk/ihateneedles.co.uk is operated by the UK branch of Aspen Pharma Limited Ireland, (“we”, “us” or “our”). Our registered office is at 6 Bell Street, Maidenhead, Berkshire, SL6 1BU and our company number is UK Reg FC035080.

If you have any queries regarding the Site or any of the information or materials contained on or in it, please contact us by by telephone on 01628 678130.

Healthcare Professionals and Members of the Public

This Site has a specific section for members of the public and a specific section for UK Healthcare Professionals. A Healthcare Professional means any person qualified to prescribe or supply medicines. This includes the medical, dental and nursing professions and other persons who in the course of their professional activities may prescribe, supply or administer a medicine, and associated, appropriate, administrative staff.

The section of this Site dedicated to Healthcare Professionals can only be accessed once the individual has confirmed that they are indeed a Healthcare Professional. This section of the Site contains advertising and promotional materials for some of our products and it is not intended that visitors who are not Healthcare Professionals access this content.

The information contained in this Site is not designed to be medical advice and is intended to be information of a general nature regarding our company and our products. Specific medical advice should always be sought from a medical practitioner.

Medical Information/Conditions

We provide product information on this Site which is intended for general information purposes only. Many pharmaceutical and medical device products listed are available upon prescription from a medical doctor or qualified medical professional only, and not all such products may be available in all countries. The product information is not intended to provide complete medical information. SHOULD YOU HAVE A MEDICAL CONDITION, PROMPTLY SEE YOUR OWN MEDICAL DOCTOR OR HEALTH CARE PROVIDER. WE DO NOT OFFER PERSONALIZED MEDICAL DIAGNOSIS OR PATIENT-SPECIFIC TREATMENT ADVICE. You should always obtain complete medical information about your prescription medicines or medical devices (including their beneficial medical uses and possible adverse effects) by discussing the appropriate use of any medicine(s) or medical devices directly with your prescribing physician or, where appropriate, other medical advisor. Medical professionals may obtain complete medical information from the product’s information leaflet. Information on these products may vary by country. Patients, physicians and other medical professionals should check with local medical resources and regulatory authorities for information appropriate to their country. In addition, current regulations in the UK limit (or even prohibit in some instances) our ability to provide information and/or to respond directly to patient questions regarding our prescription products. We, however, will respond to inquiries from and provide information to your qualified health care professional in accordance with local regulations.

Use of Information

You may freely browse the Site, but you may only access, download or use information from this Site, including any text, images, audio, and video (the “Information”) for your own non-commercial use. You may not distribute, modify, transmit, reuse, repost, or use the Information for commercial purposes, without our written permission. You must retain and reproduce each and every copyright notice or other proprietary rights notice contained in any Information you download. You should assume that everything you see or read on this Site is copyrighted unless otherwise noted and may not be used except as provided in these Terms and Conditions or in the text on the Site without our written permission. We neither warrant nor represent that your use of materials displayed on the Site will not infringe rights of third parties not owned by or affiliated with us. With the exception of the foregoing limited authorization, no license to or right in the Information, or any of our copyright or of any other party is granted or conferred to you.

Trademarks/Proprietary Rights

All intellectual property rights (including, without limitation, copyright, database rights, design rights, patents, trademarks, logos and product names) in this Site are owned by or licensed to us unless otherwise stated.

This Site may also contain or reference patents, proprietary information, technologies, products, processes or other proprietary rights of Aspen Europe GmbH, Aspen Group or its Affiliates and/or other parties. No license to or right in any such trademarks, patents, trade secrets, technologies, products, processes and other proprietary rights of Aspen Europe GmbH, Aspen Group or its affiliates and/or other parties is granted to or conferred upon you.

Disclaimer of Warranties

While we use reasonable efforts to ensure that the Information is accurate and up to date, the Information may contain technical or other inaccuracies or typographical errors. We reserve the right to make changes, corrections and/or improvements to the Information, these Terms and Conditions and to the products and programs described in such information, at any time without notice.

We make no guarantees, warranties or representations as to the correctness or accuracy of any of the Information on this Site or its possible uses. We assume no liability or responsibility for any errors or omissions in the content of the Site. Should you seek to rely in any way whatsoever upon any content contained on, or the material downloaded from this Site, you do so at your own risk.

ALL INFORMATION IS PROVIDED “AS IS.” WE EXCLUDE ALL REPRESENTATIONS, WARRANTIES, CONDITIONS AND TERMS (WHETHER EXPRESS OR IMPLIED BY STATUTE, COMMON LAW OR OTHERWISE) TO THE FULLEST EXTENT PERMITTED BY LAW. CONSEQUENTLY, THE INFORMATION SHOULD BE CAREFULLY EVALUATED BY SITE VISITORS. NEITHER ASPEN EUROPE GMBH, NOR ANY OTHER ASPEN GROUP COMPANY, NOR ANY OTHER PARTY INVOLVED IN CREATING, PRODUCING OR DELIVERING THIS SITE TO YOU SHALL BE LIABLE FOR ANY DIRECT, INCIDENTAL, CONSEQUENTIAL, INDIRECT OR PUNITIVE DAMAGES ARISING OUT OF ACCESS TO, USE OF OR INABILITY TO USE THIS SITE, OR ANY ERRORS OR OMISSIONS IN THE CONTENT OF THE SITE.

We assume no responsibility, and shall not be liable for, any damages to, or viruses that may infect, your computer equipment or other property on account of your access to, or use of, the Site and the Information or your downloading of Information. We reserve the right to block your use of the Site or discontinue this Site at any time without notice and without liability.

Liability

Nothing in these Terms and Conditions operate to exclude or limit our liability for any matter for which we are not permitted by law to exclude or limit, or to attempt to exclude or limit, our liability.

There are certain liabilities which we cannot exclude by law and nothing in these Terms and Conditions limits our liability for death or personal injury caused by our negligence or for fraud.

We are only responsible to you for losses that are a natural, foreseeable consequence of our breach of these Terms and Conditions. We accept no liability for any losses or damages which are not reasonably foreseeable arising out of or in connection with these Terms and Conditions or your use of this Site.

We will not be liable to you for any losses related to any business of yours including lost data, lost profits, lost revenues or business interruption.

Information You Supply To Us

Except for information covered by our Privacy Policy, any communication or material you transmit to the Site by electronic mail or otherwise, including any data, questions, comments, suggestions or the like is, and will be treated as, non-confidential and nonproprietary. Anything you transmit or post becomes our property or property of our affiliates and may be used for any purpose, including, but not limited to, reproduction, disclosure, transmission, publication, broadcast and posting. Furthermore we are free to use, without compensation to you, any ideas, concepts, know-how, or techniques contained in any communication you send to the Site for any purpose whatsoever including, but not limited to, developing, manufacturing and marketing products using such information.

Worldwide Products

This Site may contain information on worldwide products and services, not all of which are available in every location. A reference to a product or service on this Site does not imply that such product or service is or will be available in your location. The products referred to on this Site may be subject to different regulatory requirements depending on the country of use and product labelling may differ across countries. Consequently, visitors may be notified that certain sections of this Site are intended only for certain kinds of expert users or only for audiences in certain countries, while product information for a specific country should be verified with the local Aspen organization. You should not construe anything on this Site as a promotion or advertisement for any product or for the use of any product that is not authorized by the laws and regulations of your country of residence.

Disclaimer

Nothing on this Site constitutes an invitation or offer to invest or deal in the securities of Aspen Group. In particular, actual results and developments may be materially different from any forecast, opinion or expectation expressed on this Site and the past performance of the price of securities must not be relied on as a guide to their future performance.

Links To This Site

We have not reviewed any or all of the third-party websites which contain links to this Site and is not responsible for the content of any such off-site pages or any other sites linked to the Site. If you wish to link your website to this Site, you may only link to the home page. You may not link to any other pages within this Site without our prior written consent. Quotation or use of one or more portions of this Site in the site of any third parties without written consent is likewise prohibited.

Links To Other Sites

Links to third-party sites may be provided for the interest or convenience of visitors to this Site. The terms of use and privacy policy of the third-party site may be different. We accept no liability for links from us to others, and in particular we are not responsible for the accuracy or legality of the content thereof. We accept no liability deriving from a breach or omission in the privacy policies of third parties.

Postings To This Site

Although we may from time to time monitor or review discussions, chats, postings, transmissions, bulletin boards, and the like on the Site, we are under no obligation to do so and assume no responsibility or liability arising from the content of any such locations nor for any error, defamation, libel, slander, omission, falsehood, obscenity, pornography, profanity, danger, privacy disclosure or inaccuracy contained in any information within such locations on the Site. You are prohibited from posting or transmitting any unlawful, threatening, libellous, defamatory, obscene, scandalous, inflammatory, pornographic, or profane material or any material that could constitute or encourage conduct that would be considered a criminal offense, give rise to civil liability, or otherwise violate any law. We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity of anyone posting any such information or materials.

Consequences

If we become aware that you have violated any of these Terms and Conditions, we may immediately take corrective action, including preventing the user from using the our services and removing any information, data and content put on the Site by the user, at any moment and without notice. If we have been injured by your violation we may, in our sole discretion, seek to recover damages from you.

Revisions

We may at any time revise these Terms and Conditions by updating this posting. Please check this page for changes which have been made to these Terms and Conditions. You are bound by any such revisions and your use of this Site after a change has been posted constitutes your continued acceptance of the amended Terms and Conditions. You should therefore periodically visit this page to review the then current Terms and Conditions to which you are bound.

Data Protection and Cookies

Please refer to our Privacy Policy.

General

We will not be liable to you if we are prevented or delayed from complying with our obligations under these Terms and Conditions by anything you do or fail to do or as a result of events beyond our reasonable control.

If any provision of these Terms and Conditions is found to be invalid or unenforceable by a court, it will be severed from the rest of these Terms and Conditions which shall remain unaffected

No delay or failure by us to exercise any powers, rights or remedies under these Terms and Conditions will operate as a waiver of them, nor will any single or partial exercise of any such powers, rights or remedies preclude any other or further exercise of them.

Any notice to be given under these Terms and Conditions must be communicated by post, email or facsimile to the address most recently notified by the receiving party. Receipt of notice shall be deemed to occur at the time when the notice would in the ordinary course be delivered or transmitted.

Governing Law

These Terms and Conditions are governed by the laws of England and the courts of England will have non-exclusive jurisdiction with respect to any dispute arising under or in relation to them.

Last updated May 2018.

Aspen Pharma Ireland Limited UK Branch Website Privacy Policy

Introduction to this Website Privacy Policy

This web site (the “Site”) is owned and operated Aspen Pharma Ireland Limited UK Branch (“Aspen UK”). At Aspen UK, our unique entrepreneurial culture sets us apart. We are committed to patients, healthcare professionals and alliance partners, our employees and the community. Protecting Personal Data and respecting privacy are fundamental parts of this commitment, and this privacy policy set forth below helps to demonstrate this commitment to visitors and users of Aspen UK-owned websites. As a result, we have instituted this website privacy policy (“Privacy Policy”). Aspen UK is providing this Privacy Policy to explain how we collect, use, disclose and protect the Personal Data you submit to us when accessing and using the Site. Aspen UK is the controller within the meaning of applicable data protection laws. Aspen UK-owned websites are an Aspen UK-controlled web programme where Aspen UK owns, approves and/or engages audiences on behalf of Aspen UK.

In general, you may visit the Site and view its content while remaining anonymous by not providing any Personal Data. If you do not agree with this Privacy Policy, please do not provide us any information and do not use the Site.

As used in this Privacy Policy, “we,” “our” and “us” means Aspen UK and its affiliates.

The meaning of Personal Data

“Personal Data” is defined in data protection laws applicable in your country. It includes any information relating to an identified or identifiable natural person. This means any individual who can be identified directly or indirectly by reference to an identifier such as name, identification number, location data, online identifiers (for example, IP addresses – if they can be used to identify you) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Put simply, this includes data which either by itself or with other data held by us or available to us, can be used to identify you.

Important notice about international transfers

We are part of the Aspen Group which has databases in different jurisdictions. We may transfer your data to one of the Group’s databases outside your country of domicile. These other countries will either have different data protection laws than your country of residence or they will not have data protection laws. They may not be deemed by the European Commission as providing adequate protection for Personal Data. Even if the country to which the data is to be transferred does not require us to provide adequate protection for your data, we will nonetheless seek to ensure that data transfers to Aspen Group databases in that country are adequately protected.

The categories of Personal Data we may collect, the purpose and the lawful basis

Personal Data collected from you include the following:

Categories of Personal Data	Purpose	Lawful basis
Browsing information (IP address, browser information)	Monitoring and producing statistical information regarding the use of our platforms, and analysing and improving their functionality.	Legitimate interests – we need to perform this limited routine monitoring to make sure our website work properly, to diagnose any problems with our server and administer our Site
All information	Establishing and enforcing our legal rights and obligations and monitoring to identify and record fraudulent activity. Complying with instructions from law enforcement agencies, any court or otherwise as required by law For our general record-keeping and customer relationship management. Managing the proposed sale, restructuring or merging of any or all part(s) of our business, including to respond to queries from the prospective buyer or merging organisation. Resolving any complaints from or disputes with you.	Legitimate interest (see column on left)

In summary, we need certain categories of Personal Data because that is necessary in order to administer any contract with you (where relevant). Certain other Personal Data is processed for our legitimate interests in cases where this does not result in prejudice to you.

Data anonymisation and use of aggregated information

We may convert your Personal Data into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from that data. We may use this aggregated data to conduct market research and analysis, including to produce statistical research and reports.

In particular, we use technology to collect anonymous information about the use of this Site. For example:

1. we use technology to track which pages of our Site visitors view. We also use technology to determine which web browsers our visitors use. This technology does not identify you personally, it simply enables us to compile statistics about our visitors and their use of our Site.

2. certain pages of this Site may contain hyperlinks to other pages of it. We may use technology to track how often these links are used and which pages on our Site our visitors choose to view. Again this technology does not identify you personally — it simply enables us to compile statistics about the use of these hyperlinks.

We use this anonymous data to improve the content and functionality of this Site and consider areas and subjects which are attracting interest so that we can focus our e-mail updates (for those that wish to receive such communications). This allows us to better understand our Site visitors’ interest areas generally and therefore to improve our Site and products and services we offer.

Cookies and analytic tools

We may from time to time use cookies on our Site. Cookies are small text files that your web browser leaves on your hard drive to recognize you as a repeat user of our Site, track your use of our Site and target advertising. This allows for personalization of certain aspects of your visit to our Site. Information gathered from cookies in this way is only used on an aggregate basis. Unless a visitor specifically provides their identity to us, e.g., by registering at our Site, providing information through an online form or sending us correspondence from the Site, we will not know the identification of individual visitors. We may use cookies to store preferences; record session information; develop information about Site visitors’ preferences and interests; record past activity at a website in order to provide better service when you return to our Site; or customize web page content based on information you voluntarily provide.

The cookies that our Web sites may deploy can be divided into four categories:

1. Strictly Necessary Cookies

These cookies are essential, because they enable you to move around our Web sites and use certain features, e.g., to access secure areas of the Web site or in connection with information searches. Without these cookies, certain services you may ask for could not be provided.

2. Performance Cookies

These cookies may be used to collect information about how you use our Web sites, for example which pages you visit most often. These cookies do not collect information that identifies you. These cookies are only used to learn how our Web sites are performing and make relevant improvements.

3. Functionality & Profile Cookies

These cookies may be used to allow our Web sites to store information about choices that you make and provide you with more personal features. We may also use such cookies to ensure that onsite marketing and experience is relevant to you. The information these cookies collect may be anonymous and they cannot track your browsing activity on other Web sites.

4. Advertising Cookies

These cookies may be used to deliver advertisements that are more relevant to you and your interests. They are usually placed by advertising networks with our permission.

We use Google Analytics, a web analysis service of Google Inc. (Google) on our Site. Google Analytics uses cookies, i.e. text files stored on your computer to enable analysis of website usage by you. Information generated by the cookie about your use of this website is usually transmitted to a Google server in the United States and stored there. In case of activated IP anonymization on this website, however, your IP address is previously truncated by Google within member states of the European Union or in other states which are party to the agreement on the European Economic Area. Only in exceptional cases is a full IP address transmitted to a Google server in the United States and truncated there. On behalf this website’s owner, Google will use this information to evaluate your use of the website, compile reports about website activities, and provide the website’s operator with further services related to website and Internet usage. The IP address sent from your browser as part of Google Analytics is not merged with other data by Google. You can prevent storage of cookies by appropriately setting your browser software; in this case, however, please note that you might not be able to fully use all functions offered by this website. In addition, you can prevent data generated by the cookie and relating to your use of the website (including your IP address) from being collected and processed by Google, by downloading and installing a browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout?hl=en

We use Google Analytics on our Site with the extension “anonymizeIP()”, IP addresses being truncated before further processing in order to rule out direct associations to persons.

You can disable cookies using your Internet browser settings. Please consult your browser’s help function for information on how to disable cookies. Note that if you disable cookies, certain features of our Site may not function properly.

Facebook Pixel

We use the “Facebook Pixel” from Facebook Inc. (“Facebook”).

This allows user behaviour to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. This data is also stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/ . You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes.

Additionally, this feature enables us to display personalized advertisements (“Facebook Ads”) to website users, when they visit Facebook or other websites that also use this feature. We are interested in showing you personalized advertisements in order to make our website more interesting to you. We do not use “Facebook Custom Audience Customer List”. Due to “Facebook Custom Audiences Pixel”, your browser automatically establishes a direct connection to the Facebook server. We have no control over the extent and the further use of the data, which are collected by the use of this feature by Facebook and inform you therefore according to our knowledge level: By the integration of “Facebook Custom Audiences Pixel” Facebook receives the following information: HTTP-Header, pixel-specific data, button-click data, optional information and form field name (for details please see https://www.facebook.com/business/gdpr). If you are registered with Facebook, Facebook can assign your visit to our website to your account. Even if you are not registered with Facebook or have not logged in, there is a chance that Facebook will find out and store your IP address and other identifying features in order to track you.

You may opt-out of participation in “Facebook Pixel” by clicking https://www.facebook.com/settings?tab=ads.

The legal basis for the processing of your personal data is Art. 6 (1) (f) GDPR. For more information about data processing through Facebook, please visit https://www.facebook.com/about/privacy. Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation: (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

Disclosure of your Personal Data to third parties

We may disclose your Personal Data to third parties, including but not limited to as follows:

1. within our group of companies for the purposes of use described in this Privacy Policy;

2. to third parties who supply services to us and who help us and our group of companies to operate our business. For example, sometimes a third party may have access to your Personal Data in order to support our information technology;

3. to our legal and other professional advisers;

4. as necessary in order to comply with a legal requirement, to protect vital interests, to protect the security or integrity of our databases or this Site, to take precautions against legal liability;

5. to regulatory authorities, courts and governmental agencies to comply with legal orders, legal or regulatory requirements and government requests; and

Security of Personal Data

We endeavour to use appropriate technical and physical security measures to protect Personal Data which is transmitted, stored or otherwise processed by us, from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access, in connection with our Site. These measures include computer safeguards and secured files and facilities. Our service providers are also selected carefully and required to use appropriate protective measures. In certain areas, Aspen UK uses industry-standard SSL-encryption to protect data transmissions. Most current browsers support the level of security needed to use these areas.

In particular, we endeavour to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including as appropriate: (a) pseudonymisation (such as where data is separated from direct identifiers so that linkage to an identity is not possible without additional information that is held separately) and encryption, (b) ensuring the ongoing confidentiality, integrity, availability and resilience of systems and services used to process your Personal Data, (c) ensuring the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident; and (d) ensuring a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational security measures.

Retention period or criteria used to determine the retention period

We keep your Personal Data for as long as it is necessary to do so to fulfil the purposes for which it was collected as described above.

The criteria we use to determine data retention periods for Personal Data includes the following: (i) Retention in case of queries.  We will retain it for a reasonable period after the relationship between us has ceased (up to 6 months) in case of queries from you; (ii) Retention in case of claims.  We will retain it for the period in which you might legally bring claims against us (in Germany this means we will retain it for 10 years) if and to the extent we have entered into any contract with you; (iii) Retention in accordance with legal and regulatory requirements.  We will consider whether we need to retain it after the period described in (ii) because of a legal or regulatory requirement.

If your application for employment is successful and you commence employment with Aspen UK, your Personal Data will be transferred to your personnel file and will be processed for employment purposes. If your application for employment is not successful, we will keep your Personal Data for a period compliant with applicable laws, after notification that your application was not successful.

If you would like further information about our data retention practices please contact us (see “Contact Us” below).

Your rights under data privacy laws

You have various rights under data privacy laws in your country. These may include (as relevant): the right to request access to the Personal Data we hold about you; the right to rectification including to require us to correct inaccurate Personal Data; the right to request restriction of processing concerning you or to object to processing of your Personal Data, the right to request the erasure of your Personal Data where it is no longer necessary for us to retain it; the right to data portability including to obtain Personal Data in a commonly used machine readable format in certain circumstances such as where our processing of it is based on a consent; the right object to automated decision making including profiling (if any) that has a legal or significant effect on you as an individual; and the right to withdraw your consent to any processing for which you have previously given that consent. Please be aware that some of these rights will only become relevant when changes to data privacy laws come into force in May 2018. You can also lodge a complaint with a supervisory authority in the country of your residence.

Please see “Contact Us” if you wish to exercise any of these rights (as relevant).

Links to Other Websites

This Site may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators. We do not control these websites and are not responsible for their data or privacy practices. We urge you to review any privacy policy posted on any site you visit before using the site or providing any Personal Data.

Updated and changes to this Privacy Policy

We may decide to change this Privacy Policy. If the change is fundamental or may significantly affect you, we will provide you with the updated Privacy Policy in advance of the change actually taking effect. We encourage you to review the content of this Privacy Policy regularly.

Contact Details

If you have any queries or complaints about our compliance with this Privacy Policy, or if you would like to make any recommendations or comments to improve the quality of our Privacy Policy, please contact us at:

E-Mail: aspenmedinfo@professionalinformation.co.uk

Public Scientific Service Phone: +44 1748 828391

There are Terms and Conditions associated with your usage and viewing of this site. These can be accessed by clicking on the link ‘Terms of Use and Conditions’ within the website footer (next to ‘Privacy Policy’).

Be sure to include your email address and telephone number with your correspondence.

Alternatively, write to: Aspen UK, 6 Bell Street, Maidenhead, Berkshire, SL6 1BU

Last updated: July 2018