Privacy Policy

Privacy Policy

PRIVACY NOTICE

A. Menarini Singapore Pte. Ltd., acting through its Malaysia Branch ( Menarini”, " we", " us" or " our") wishes to inform you that your personal data is processed in accordance with the applicable privacy and data protection laws including Malaysia's Personal Data Protection Act 2010 (“ Data Protection Laws”).

  1. Data Controller and Contact Person

The data controller is A. Menarini Singapore Pte Ltd., a company incorporated in Singapore with company registration number 200504607E, acting through its Malaysia Branch, located at B-18-2, Level 18, The Ascent Paradigm, No. 1, Jalan SS7/26A, Kelana Jaya, 47301 Petaling Jaya, Selangor Darul Ehsan, Malaysia.

If you have any inquiries or complaints regarding the processing of your personal data by us, please contact our Data Protection Officer at: [email protected].

  1. Types of Personal Data We Collect and Process

In connection with the 1000 Untold Stories campaign (" Campaign"), we collect the following categories of personal data from you:

  1. photograph of you and your infant. Please note that the processing of your photograph by the AI tool to extract your facial features and generate an animated likeness constitutes the processing of biometric data, which is sensitive personal data under Data Protection Laws. Processing of this data will only occur upon your explicit consent;
  2. your email address; and
  3. any such information as we deem necessary or appropriate from time to time in connection with your dealings and/or relationships with us.

(collectively, " Personal Data").

The supply of your Personal Data is voluntary. However, if you choose not to provide us with your Personal Data, we may not be able to generate your personalised AI-animated video or deliver it to you, and you will not be able to participate in the Campaign.

To the extent that you disclose to us any personal data of another individual, you warrant and agree that:

  1. you have obtained such individual's consent for the disclosure of such personal data to us and the processing of their personal data by us; or
  2. where that individual is below 18 years of age, you are the parent of that individual, and you have the authority to consent on his/her behalf, and you hereby provide such consent on his/her behalf to the disclosure and processing of his/her personal data by us.
  1. Source of Personal Data

We may collect your Personal Data directly from you such as when you provide us with your information through the website (" Website") or any communications with us. We may also generate your Personal Data, including through creation of a video using AI.

  1. Why and How We Process Your Personal Data

Your Personal Data is processed for the following purposes:

  1. Creation, Delivery and Hosting of Your Personalized AI-Generated Video

    AI Video Generation and Delivery Your Personal Data is collected primarily to generate your personalised AI-animated video (" Video") and to deliver a unique, private link to your email inbox through which you may view it. The Video link is accessible only to you via the email address you provide.

    Your photograph is processed by an AI rendering workflow within the Google Cloud Platform to generate the animated Video output.

    Your email address and photograph are automatically and permanently deleted within 24 hours of your Video being generated. They are not retained for any other purpose.

    Your photograph is shared within the Google Cloud Platform solely for the purpose of generating your animated Video. Your photograph is processed within the Google Cloud Platform under our instruction, and Google Cloud Platform is prohibited from using it for any other purpose, including training of AI models. Your Personal Data is deleted from within the Google Cloud Platform within 1 hour of its upload.

    We may also process your Personal Data through big data analytics systems for the purposes described in this Privacy Notice. For these purposes, ‘big data’ means the large-scale and ongoing processing of personal data aggregated from multiple sources, including to analyse behaviours, identify trends, or classify users.

    In addition, Menarini retains rights to the Video and may, subject to the consents you provide, reproduce and distribute the Video (in any way and in any format at Menarini’s discretion) through the following channels: linking the Website to other digital channels including Facebook; displaying the Video at conferences and events; sharing the Video across all Menarini social media channels and communications; and distributing the Video through third-party agencies running campaigns or publishing articles.

  2. Video Retention and Display Your Video will be retained on this Website for as long as the Website remains active, unless you request its removal. Your Video will be used for the promotion and marketing of the Campaign and Dermatix products for as long as the Website remains active, including but not limited to display at conferences, events, and exhibitions, distribution through third-party agencies and media partners, and inclusion in articles, publications, and other marketing and campaign materials.
  3. Social Media Publication With your separate and additional consent, your Video may be shared on Menarini's official social media channels. This consent is optional and independent of your consent to generate the Video. You may decline social media sharing without affecting your ability to use the microsite or receive your Video. If you have consented to social media sharing and subsequently wish to withdraw that consent, you may contact [email protected]to request removal of your Video from Menarini's social media channels, though removal of content already published cannot be guaranteed.
  4. Statistical and Legal Purposes Your Personal Data may also be processed to the extent strictly necessary to comply with Data Protection Laws and regulations, to ensure the proper functioning and security of the microsite, and to establish or defend legal claims in the interest of Menarini, to the extent permitted under Data Protection Laws.
  1. Security and Processing

All data is entered into Menarini's systems in full compliance with Data Protection Laws, including appropriate security and confidentiality measures, and in accordance with the principles of lawfulness, fairness, and transparency.

While we strive to protect your Personal Data, processing always carries certain risks, including potential unauthorized access, alteration, or loss beyond our reasonable control. To address these risks, we apply appropriate technical and organizational safeguards and maintain compliance with applicable Data Protection Laws.

  1. Disclosure to Third Parties

Your Personal Data is processed electronically and manually in accordance with the purposes described in this Privacy Notice and is accessible only to Menarini and Menarini Group staff who require access in order to perform their job duties, including technical, IT, marketing, and compliance staff, as well as their supervisors.

Your Personal Data may also be disclosed to the following categories of recipients, including in countries outside of Malaysia for purposes described in this Privacy Notice (" Third Countries"):

  1. AI processing provider — your photograph is shared with Google Cloud Platform, solely for the purpose of generating your Video. Google Cloud Platform acts as a data processor under our instruction and is contractually prohibited from using your Personal Data for any purpose other than video generation, including the training of AI models. Your photograph is deleted from the Google Cloud Platform upon completion of processing, consistent with the one-hour deletion schedule described in this Privacy Notice;
  2. IT and cloud services providers — third-party providers who supply technical infrastructure required to operate this Website, including hosting and cloud computing services, to the extent necessary for delivery of the service;
  3. Social media platforms — where you have provided your separate optional consent to social media sharing, your Video may be shared on [Platform Names]. Once published on a third-party platform, that platform's own privacy policy and data practices apply.
  4. Institutions, authorities, and public bodies — where required for their institutional or regulatory purposes, or where disclosure is required by applicable law;
  5. Group companies — other companies within the Menarini Group, including those based in Third Countries, where necessary for compliance, audit, or internal oversight functions, including enforcement of the Menarini Group Code of Conduct.

By agreeing and consenting to this Privacy Notice, you also consent to such transfer of your Personal Data to places outside Malaysia. Cross-border transfer of your Personal Data is conducted in accordance with applicable Data Protection Laws.

Each recipient shall receive only the data strictly necessary for their respective function and shall be required to process it solely for the purposes set out in this Privacy Notice and in compliance with Data Protection Laws. Recipients act, as the case may be, as independent controllers, processors, or persons authorised to process personal data.

With the exception of the above, your Personal Data will not be shared with, or disseminated to, any third party that does not perform a commercial, professional, or technical function for Menarini.

  1. Your Rights

By contacting us via the Data Protection Officer at the addresses indicated above, you can, at any time, exercise your rights under the Data Protection Laws as follows:

  1. Request access to and/or correction of your Personal Data.
  2. Limit the processing of your Personal Data, including personal data relating to other persons who may be identified from that personal data.
  3. Withdraw your consent at any time; however that shall not impair the lawfulness of the processing carried out before consent withdrawal.
  4. Request takedown of your Video at any time. Upon receipt of your request, your Video will be removed as soon as practicable, and in any event within 72 hours.
  1. Language of this Privacy Notice

This Privacy Notice is made available in both the English language and in Bahasa Malaysia. Both texts are equally original. To the extent that there are any inconsistencies or different interpretation between both texts, the English version shall prevail.