Social Media: Data privacy / Comment policy / Imprint
This document contains the relevant legal notes which are part of our Social Media Channels.
Legal notes are structured as follows:
Social Data Privacy Statement
The #MYCONTRACEPTION social media channels (hereinafter the “Social Media Channels“) are provided by Bayer AG (hereinafter “us” or “we”). For further information regarding the provider of the Social Media Channel, please refer to our imprint.
1.Handling of personal data
In the following we wish to provide you with information on how we handle your personal data when you use our Social Media Channels. Unless otherwise indicated in the following chapters, the legal basis for the handling of your personal data results from the fact that such handling is required to make available the functionalities of the Social Media Channels requested by you (Art. 6(1)(b) General Data Protection Regulation).
1.1.Using our Social Media Channels
1.1.1. Using comment-, message- or chat-functions
You can contact us directly via the comment-, message- or chat-functions available on our Social Media Channels. The information provided by you in this context will exclusively be processed for purposes of responding to you, unless other purposes are indicated in this Privacy Statement.
1.1.2. Information on side effects and quality complaints
The Social Media Channels are not intended or designed for communications regarding undesired side effects, lack of therapeutic effect, medication errors, grey market products/counterfeit medicine, incorrect or off-label use, quality complaints and/or other issues regarding the safeness or quality of Bayer products. If you wish to report side effects or make a quality complaint, please contact your health care professional (e.g. physician or your pharmacist), your local health authority, or use our website for the report of undesirable side effects.
If you nevertheless report to us undesirable side effects or other issues regarding the safeness or quality of Bayer products, we will be legally bound to deal with your communication and may have to contact you for clarification purposes. Subsequently, we have to notify the competent health authorities of the issues reported by you. In this context, your information may be forwarded in pseudonymised form, i.e. no information by which you may be directly identified will be passed on. We may also have to forward these pseudonymised notifications to our group companies and cooperation partners, to the extent these are likewise obliged to notify their respectively competent health authorities.
1.1.3 Using a like-button function
Anyone who clicks the "Like"-button sends information to the platform provider, who again provides us with aggregated information about the average age structure, place of residence, gender, language and activity of all users who used the like-button function with regard to our respective Social Media Channel. At no time do we receive information on individuals. For more details on the data the platform provider collects in this regard, please consult the below (D) referenced privacy statement of the platform provider.
1.2 Social Media Management Tool
We use a social media management tool to administrate our accounts and manage the content we share on our Social Media Channels as well as our visitors’ engagement with us (Art. 6(1)(f) General Data Protection Regulation). For this purpose, any of your engagements with our Social Media Channels (e.g. comments, likes, posts, messages) will be transferred and stored in our social media management tool.
The social media management tool allows us to analyse the overall engagement of our visitors with our Social Media Channels to e.g.
- determine most active visitors;
- determine sentiment via automated and manual scoring;
- identify and profile brand advocates and key influencers;
- filter messages to identify and delete spam.
1.3 Social Media Listening
We conduct so called social media listening. Social media listening is the process of identifying and assessing what is being said about a company, individual, product or brand on social media channels. We use social media listening services exclusively on publicly accessible content to
- perform keyword searches across social media channels;
- view the volume of conversation whenever users interact with our brand;
- view visual analytic displays of conversation trends over a specified time range;
- search, filter and analyse conversation streams and
- monitor publicly available opinions, statements or other interactions on social media channels from certain individuals or entities that are important for us and our business (so called thought leaders).
We use the insights we receive from social media listening to
- better understand sentiment, intent, mood and market trends as well as to better understand our customers’ or other stakeholders’ needs and thereby improve our services and products and
- identify side effects, lack of therapeutic effect, medication errors, grey market products/counterfeit medicine, incorrect or off-label use, quality complaints and/or other issues regarding the safety or quality of our products.
We perform social media listening on the legal basis of the statutory permission which allows a processing that is necessary for pursuing a legitimate interest, namely the above described purposes on what we use the insights of social media listening for (Art. 6(1)(f) General Data Protection Regulation).
1.4.Transfer of data for commissioned processing
For the administration of our Social Media Channels we will use specialised service contractors, who will have access to the personal data of all users contacting us via such Social Media Channel. Such service contractors are carefully selected and regularly monitored by us. Based on respective data processor agreements, they will only process personal data upon our instruction and strictly in accordance with our directives.
1.5.Processing of data outside the EU / the EEA
Your data will in part also be processed in countries outside the European Union (“EU”) or the European Economic Area (“EEA”), which generally have a lower data protection level than European countries. In such cases, we will ensure that a sufficient level of protection is provided for your data, e.g. by concluding specific agreements with our contractual partners (copy available on request), or we will ask for your explicit consent to such processing.
2.Information regarding your rights
The following rights are in general available to you according to applicable data privacy laws:
- right of information about your personal data stored by us;
- right to request the correction, deletion or restricted processing of your personal data;
- right to object to a processing for reasons of our own legitimate interest, public interest, or profiling , unless we are able to proof that compelling, warranted reasons superseding your interests, rights and freedom exist, or that such processing is done for purposes of the assertion, exercise or defence of legal claims;
- right to data portability;
- right to file a complaint with a data protection authority;
- You may at any time with future effect revoke your consent to the collection, processing and use of your personal data.
If you wish to exercise your rights, please address your request to the contact indicated below. ( see 3.).
For any questions you may have with respect to data protection, please send us a private message via the message function on our Social Media Channels or contact our company data protection officer at the following address:
Group Data Protection Officer
4.Processing of personal data by the platform provider
Please note that the platform provider of the Social Media Channels will also process your personal data when you visit our Social Media Channels. For further information, please consult the privacy statement of the platform provider of the respective Social Media Channel.
5. Amendment of this Privacy Statement
We may update our Privacy Statement from time to time. Updates of our Privacy Statement will be published on our Social Media Channels. Any amendments become effective upon publication on our Social Media Channels. We therefore recommend that you regularly visit the Social Media Channels to keep yourself informed on possible updates.
Comments policy / Netiquette
As Bayer is a company in a very sensitive and regulated industry, we have to follow some specific rules under which we have to operate in any kind of communication channel. Additionally, many of our medicines are used to treat serious medical conditions. Also prescription only contraceptives require thorough medical counselling before individual usage. That is why we take great care to avoid unmonitored or unverified medical advice being posted here. Therefore Bayer reserves the right to remove posts, comments, pictures or videos from our wall at our sole discretion, when they are not consistent with our guidelines or the regulatory rules of our industry. This might be not very Web 2.0 – but as a healthcare company, we have the responsibility to manage our social media channels appropriately in line with the existing regulations.
Please take a few minutes to read the information below for more details about why content may need to be removed from our page:
6.1.Talking about products
Statements from users on our social channels do not necessarily reflect our opinion. However, we still have to meet all the regulations that govern our industry, including the prohibition of promoting any prescription only drug to an audience that does not consist of healthcare professionals. That's why we will remove any post that references a pharmaceutical brand from any company including Bayer, no matter if it is positive or negative.
6.2.Talking about medical issues
The content available on our social media channels are for informational purposes only. The information is not intended to be a substitute for individual medical advice, diagnosis, or treatment. Please always consult your doctor or healthcare specialist for individual medical advice.
All medicines may cause side effects. If you would like to report an adverse event or product complaint, please find use this contact .
6.3.Talking about tonality
As we respect all visitors of this page in return we ask that everyone treat each other with respect, even if we don't agree from time to time. However, Bayer does reserve the right to delete any posting at its sole discretion. We don't want to censor this page but there might be a situation in which we are required to remove your post. If you use disrespectful language, your post gets pulled (and it might get screened by the social platform’s [Facebook’s] profanity filter before being posted in the first place). In addition to vulgar language, we'll be screening the following:
- Personal insults or degrading comments of any kind, disparaging comments about institutions, organizations or companies, sexist or racist comments, or hate propaganda, calls to violence of any kind, calls to join in demonstrations or rallies of any political orientation
- Any violation of the rights of third parties, including in particular copyrights,
- Posts and comments that do not relate to the messages under discussion or are off-topic
- Offering goods or services, of either a commercial or private nature, or using this social channel as an advertising space
- Spam, i.e. any form of automatically generated content or repeatedly posting the same comment.
Gross or repeated violations, may lead to the exclusion of any further messages from a user and the disabling of his or her account for this social page (where applicable).
In the spirit of this community, we ask that anyone participating in the conversation keep it friendly, respectful and relevant. The style of communication on this channel should be characterized by:
- Treat every other user as you would like to be treated yourself.
- Everyone has the right to express their own opinion. Please respect this and not try to force your opinion on anyone else.
- Respect the rights of others
We believe that Social Media offers a great opportunity for dialogue and learning about contraception. We look forward to sharing and discussing with you. Let's create a space to exchange our ideas.
Bayer AG, Leverkusen, Germany
Represented by the Management Board:
Werner Baumann, Chairman
Liam Condon, Sarena Lin, Wolfgang Nickl, Stefan Oelrich, Heiko Schipper
51373 Leverkusen, Germany
Tel.: +49 (0)214 30-1
E-mail: Inquiries can be sent to firstname.lastname@example.org or using our contact form.
Entry in the Commercial Register of the Cologne District Court
(Amtsgericht): HRB 48248
Turnover tax ID no.: DE 123659859
Therapeutic Area: Innovative Women's Healthcare
13353 Berlin, Germany