CONSENT NOTICE

Please read this consent notice carefully before accessing, using or providing your details for the PACE Pg initiative (Programme).

1. Data Fiduciary and purpose. Nutricia International Private Limited (Nutricia) will collect and process your data (including personal data), directly or indirectly through its appointed service providers acting on its behalf, for the purpose of registering you for the Programme, administering and facilitating your participation in the Programme, creating and maintaining your Programme account, delivering Programme-related content and communications, enabling access to educational materials and learning activities, administering quizzes, questionnaires, assessments, competitions and related participation activities, recording your attendance, learning progress, course completion and feedback, issuing participation-related certificates or recognition where applicable, and maintaining necessary Programme records.
2. Data collection and personal data. The personal data collected may include, your name, professional title, email address, telephone number, city and State, medical college name, speciality or other professional information that you provide, Programme account and user-identification details, login and technical-log information, and records relating to your participation in the Programme, including attendance, access to learning materials, learning progress, course completion, quiz, questionnaire and assessment responses and results, feedback, communications, and any certificate, recognition or competition-related record issued or maintained in connection with the Programme. Nutricia may also collect any additional professional information that you voluntarily provide in connection with the Programme.
3. Platform and disclosure. The Programme will be administered through a learning management system (LMS) operated by a service provider engaged by Nutricia. Your personal data may be made available to the LMS and other service providers supporting the Programme solely to the extent necessary to host, operate, administer, maintain, secure and support the Programme platform and related services, including account management, access to learning materials, communications, participation tracking, quizzes, questionnaires, assessments, feedback, certification and competition administration. Nutricia will require the service provider to process your personal data subject to applicable confidentiality, security and data-protection safeguards.
4. Further recipients and international access. Nutricia may disclose or otherwise make your personal data available to: its group entities; academic and Programme partners, including educational-content providers and lecturers, some of whom may be located outside India; service providers supporting the operation and delivery of the Programme, including providers of LMS, hosting and cloud infrastructure, information technology, technical support, communications, analytics, assessment, certification, competition and administrative services; and professional advisers, auditors, insurers, regulators, governmental authorities or other persons where disclosure is necessary to comply with applicable law, enforce or protect Nutricia’s legal rights, or respond to a lawful request, as permitted under applicable law. Such recipients may access, store or process your personal data outside India, including in the jurisdictions in which Nutricia’s group entities, academic and Programme partners, or service providers operate, subject to applicable law. Nutricia will require service providers processing personal data on its behalf to maintain appropriate confidentiality, security and data-protection safeguards and to process the data only, as permitted under applicable law. Academic and Programme partners may use the personal data made available to them only to the extent necessary to provide educational content, lectures, assessments, certification, competitions or other Programme-related activities. Nutricia does not sell or rent your personal data.
5. Programme records and LMS data. Nutricia may process your Programme registration, account and profile details; professional and institutional information; LMS user identifiers; login, device, browser, IP address and technical-log information; records of access to Programme materials and participation in Programme activities; attendance; learning progress; course-completion; quiz, questionnaire and assessment responses and results; feedback; communications; and records relating to certificates, recognition, competitions, awards, consent, withdrawal requests and grievances, but only to the extent generated in connection with, or reasonably necessary for, the specified purposes or as permitted under applicable law.
6. Legal basis for collecting and using personal data. We process your data only where we have an appropriate basis for doing so under applicable law. Depending on the nature of your interaction with us, the purposes for which your personal data is collected, and the products or services we provide, our processing may be based on one or more of the following grounds:
   1. Contractual necessity: Our use of your personal data is necessary to perform our obligations under any contract with you or to take steps prior to entering a contract with you.
   2. Voluntary provision for a specified purpose: You have voluntarily provided your personal data to us for the specific purposes of enabling your access to and participation in this Programme, facilitating scientific, medical and professional interactions, managing events and engagements, communicating relevant information, providing support, maintaining records of your interactions, and administering the services made available through the LMS or any other tools.
   3. Legitimate uses: We may process your personal data where such processing is necessary or otherwise permitted under applicable law, including:
      1. to perform functions or comply with requirements imposed by applicable law, or to cooperate with governmental, regulatory or judicial authorities acting within their lawful powers;
      2. to comply with applicable legal, regulatory, judicial or governmental requirements, including maintaining records, responding to lawful requests from competent authorities, complying with reporting and disclosure obligations, preventing, detecting or investigating fraud or unlawful activities, and fulfilling statutory obligations applicable to our business;
      3. to comply with any judgment, decree, order, award or other legally binding decision of a court, tribunal, regulatory authority or other competent body;
      4. to respond to medical emergencies involving a threat to the life or immediate health of any individual, or to facilitate the provision of medical treatment or health services during an epidemic, outbreak of disease or other public health emergency;
      5. to take measures necessary to ensure the safety of, or provide assistance or services to, individuals during disasters, emergencies or other situations affecting public safety or public order;
      6. for purposes relating to our employment relationship with current, former or prospective employees, including administering employment benefits, protecting confidential information, trade secrets and intellectual property, maintaining information security, preventing corporate espionage, managing workplace safety, and safeguarding the Company against loss or liability; and
      7. for any other purpose that is permitted or required under applicable law.
   4. Consent: We process your personal data on the basis of your consent. Where you have given consent, but you later change your mind, you may withdraw your consent by contacting us and we will stop doing processing your personal data. Upon receipt of your request, we will process the withdrawal of consent and remove or anonymize your personal data, to the extent permitted by applicable law, within seventy-two (72) hours. You may withdraw your consent at any time by using the unsubscribe link in our communications (if any), contacting us at care.india@danone.com. Withdrawal of consent will not affect the lawfulness of processing undertaken before withdrawal. Upon withdrawal, Nutricia will cease consent-based processing of the relevant personal data, unless continued processing is required or permitted by applicable laws. However, please note that, if you withdraw your consent, this may impact our ability to provide our products and associated services to you, including the Programme.

      Your consent is voluntary. If you do not provide the data required to register for and administer the Programme, Nutricia may be unable to provide Programme access or related services. This notice and consent request are available in English. You may request access to it in a language specified in the Eighth Schedule to the Constitution by contacting care.india@danone.com.

7. Retention and deletion. Nutricia will retain your personal data for the duration of your participation in the Programme, any related activities, and your access to the LMS or other Programme resources made available by Nutricia, and for a period of 5 (five) years following the end of the later of such participation, activity or access. Upon expiry of that period, Nutricia will securely delete, anonymise or otherwise de-identify your personal data, unless its retention is necessary for the specified purposes or is in compliance with applicable law.
8. Your rights and grievance. You may request information about the personal data processed about you and may seek correction, completion, updating or erasure of inaccurate, incomplete or outdated data, subject to applicable law. You may raise a grievance with Nutricia at care.india@danone.com .
9. Privacy Policy. Further information regarding Nutricia’s processing activities, data-sharing practices, your rights and the applicable terms and conditions is available in the Nutricia Privacy Policy Privacy Policy.