October 2026

This Privacy Notice is addressed to our business partners, in particular health care professionals, we engage within the context of our business activities, which may include informing about our products and services and for other promotional and non-promotional activities (hereinafter “business partner” or “you”).

Novartis as Data Fiduciary (Data Controller) is responsible for deciding why and how personal data is processed. It may exercise this responsibility alone or jointly with other company(-ies) in the Novartis group acting as joint Data Fiduciary(ies) (joint Data Controllers). In this Privacy Notice, “Novartis”, “we” or “us” refers to the Novartis India entity processing your personal data, as listed at https://www.novartis.com/in-en/about/india-sitelocations. 

Where you are not comfortable with English, we will provide you the notice information in another language, including a language specified in the Eighth Schedule to the Constitution of India, upon request, within a reasonable period. 

This Privacy Notice is addressed to: 

  • healthcare professionals with whom we create or maintain a relationship
  • our customers or prospects who are natural persons (such as self-employed pharmacists, purchase or procurement teams);
  • the representatives or contact persons of our customers or prospects who are legal entities (such as wholesale pharmacists) and other Business Partners (e.g., distributors, suppliers, consultants, agents).

We invite you to carefully read this Privacy Notice, which sets out in which context we are processing your personal data and explains your rights and our obligations when doing so.

 

What information do we have about you?

Information Novartis may have about you may either be directly provided by you, such as when you share personal data with us or we receive information through your interactions with us, by our business partners (i.e. the organization for whom you work), or by third parties (e.g. our external service providers or medical agencies). We may further obtain your personal data through public sources where you may publish information voluntarily in a professional context or other trusted publicly available sources (such as PubMed, Clinical Trials.gov, congress websites or university websites). Information about you may also be inferred from personal data we have about you. 

We may collect various types of personal data about you, such as:

  • your general professional contact and identification information (e.g. name, first name, last name, gender, email and/or postal address, fixed and/or mobile phone number);

  • your function and professional activities/experience (e.g. title, position, name of company, as well as, for health care professionals, first specialty, second specialty, year of graduation, publications, congress activities, awards, biography, education, links to universities, expertise and participation in/contribution to clinical trials, data generation projects, guidelines, editorial boards, organizations, conferences, events, and speaking engagements);

  • payment information (e.g. credit card details, bank account details, PAN Card details, VAT or other tax identification number

  • Novartis unique business partner ID and profile; 

  • your electronic identification data where required for the purpose of delivering products or services to us (e.g. login, access right, passwords, badge number, IP address, online identifiers/cookies, logs, access and connection times, image recording or sound such as badge pictures, CCTV of Novartis premises or voice recordings); 

  • information regarding your utilization, responses and/or preferences including in terms of types of messages discussed, channels of communication, and time and frequency. 

  • user behavior and interaction with our websites, online portals, and electronic communications (such as website usage analytics information, or email click, read and/or open rates);

  • publicly available information from professional social media interactions and/or membership in groups (such as public blogs, forums, posts or interactions via social media accounts relating to the professional/therapeutic area);

  • data which relates to our products and services; data which relates to competitor products and services

  • information about the promotional, scientific and medical activities/interactions you have with us, including services you may provide to us and potential future interactions; and

  • other data you provide to us, such as when filling out forms, making an enquiry, responding to a survey, during events you attend, answers given during a conversation or participating in market research.

If you intend to provide us with personal data about other individuals (e.g. your colleagues), you must provide a copy of this Privacy Notice to the relevant individuals, directly or through their employer.

 

For which purposes do we use your personal data and why is this justified?

We will always process your personal data for a specific purpose, and we will not process such personal data if we do not have a proper justification foreseen in the law for that purpose. Therefore, we will only process your personal data if:

  • we have obtained your prior consent 

  • the processing is necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request.

    or

  • the processing is necessary for certain legitimate uses such as to comply with our legal or regulatory obligations  

In the table below, we set out for which purposes we process your personal data and indicate the corresponding legal justification/basis (where required).

PurposeJustification (legal basis)

Contract management

We process your personal data for the purpose of initiating or performing a contract (e.g. a specialist lecture), including as necessary for:

  • implementing tasks in preparation of or to perform existing contracts; 

  • granting you access to our training modules allowing you to provide us with certain services; 

  • evidencing transactions and ensuring transparency on transfer of value; and

  • billing and invoicing.

To the extent we enter a contractual relationship with you we will collect certain personal data in the context of that contractual relationship. Our processing of such data which is necessary to perform the negotiation or execution of the contract will be based on your consent given via contract

Consent

 

Data voluntarily by you

  • to establish a business relationship/ contractual relationship with you

Data voluntarily made publicly available by you. 

Business partner relationship management

We process your personal data to manage, maintain and organize our professional relationship with you, including as necessary for:

  • contacting you with marketing, medical and other communications regarding products, therapeutic areas or services that we promote, including in the form of personal visits, calls, emails and mobile messaging; 

  • managing, evaluating, documenting and maintaining our relationship with you (e.g. through our databases), including segmentation and profiling activities to provide appropriate and educational, scientific and business-related support and care tailored to your specific characteristics, needs and preferences; 

  • inviting you to events or  meetings initiated or sponsored by us (e.g. medical events, promotional events, speaker events, conferences); 

  • providing you with appropriate, adequate and updated information about diseases, drugs as well as our products and services; 

  • answering your requests and providing you with efficient support; 

  • sending you surveys (e.g. to help us improve your future interactions with us);

  • tracking our activities (e.g. measuring interactions or sales, number of appointments/calls, website usage, or email click, read and/or open rates); 

  • managing, plan and executing communications and interactions with you (e.g. through the use of AI-assisted technology and operation of a database keeping records of interactions with business partners or managing call planning as well as call reporting); and

  • improving the quality of our interactions and services by adapting our offering to your specific needs. 

  • to administer, organize, maintain and optimize our professional relationship with you, and ensure efficient business communication.

  • to develop a proximity and trustful professional relationship with you; 

  • to provide knowledge to you about Novartis medicines and scientific developments.

  • to promote innovation in the pharmaceutical field. 

  • to manage Novartis human and financial resources and optimize our interactions with you; 

  • to provide you with information and insights which may help you with taking technically and professionally well-informed decisions so that the right medicine may reach the patient; 

  • to offer our products and services to our customers.

Our goal is to personalize our relationship with you, and – depending on your personal characteristics, history of interactions, needs and preferences – to provide you with the most relevant information and to contact you in the best possible way. 

To achieve our relationship with our business partner in ensuring effective, adequate and proportionate communication and interaction with you, including optimizing the content, means and timing of our communications, we will segment our business partners, and allocate you to a profile that matches the information that we have about you (such as your personal characteristics, expertise, preferences, prior interactions with Novartis, responses to marketing communications, and/or areas of interests). 

Your profile will be adapted and will evolve over time, and will ultimately drive what type of communications we send you, what content they contain, and when and through which channels these communications occur. 

Our segmentation and profiling activities may involve the use of analyzing your personal data and other information, such as aggregated and/or estimated sales or market data, or for predicting future trends and behavior. 

To the extent we enter into a contractual relationship with you we will collect certain personal data in the context of that contractual relationship. Our processing of such data which is necessary to perform the negotiation or execution of the contract will be based on the legal basis of the contractual necessity.

Depending on local law requirements or local guidance, where our business partnering activities, including segmentation and profiling, go beyond usual business practices or where otherwise required by law, we will obtain your prior consent. In such case your consent is the legal basis for our processing.

Consent

 

Fulfilment of our legal and regulatory obligations

We process your personal data to fulfil our legal and regulatory requirements, including as necessary for

  • ensuring and documenting compliance with reporting and other legal obligations (such as regulatory monitoring and reporting, adverse event and product safety related obligations, complying with our policies and local legal requirements, anti-corruption and anti-bribery laws, tax laws, transparency disclosure obligations, and/or statutory retention obligations);

  • archiving and record keeping; and

  • any other purposes imposed by law and authorities.

 

To comply with our legal or regulatory obligations 

 

Managing company activities

We process your personal data for our operational business purposes to manage and protect our company, including as necessary for:

  • preserving the company’s economic interests and ensuring compliance and reporting (such as complying with our policies and local legal requirements, tax deductions, managing alleged cases of misconduct or fraud; conducting audits and defending litigation);

  • managing our IT resources, including infrastructure management and business continuity, and protect the security of our IT-systems, architecture and networks; 

  • preventing fraud or criminal activity, or misuses of our products or services;

  • managing mergers and acquisitions involving our company; and

  • achieving our corporate social responsibility goals

  • to benefit from cost-effective services (e.g. we may opt to use certain platforms offered by suppliers to process data); 

  • to prevent fraud or criminal activity, misuses of our products or services as well as the security of our IT systems, architecture and networks;

  • to sell any part of our business or its assets or to enable the acquisition of all or part of our business or assets by a third party; and 

  • to meet our corporate and social responsibility objectives.

Consent

Our processing activities may include the use of artificial intelligence (AI) when processing your personal data for the purposes listed above. We may also occasionally optimize such AI solutions by training or fine-tuning them with some limited amount of your personal data, always ensuring that we are not compromising your privacy, rights and interests, and remain within the realm of our legal basis as defined above. When using AI Novartis does so in compliance with applicable laws and adheres to human-centric principles, applies appropriate transparency, and uses AI responsibly, always applying adequate security measures. 

You can obtain further information on the purposes and applicable legal justification/basis, including the balancing test of the above specific interests, upon an express request to Novartis 

 

Who has access to your personal data and to whom are they transferred?

In the course of our activities and for the same purposes as those listed in this Privacy Notice, your personal data may be accessed by or transferred to the following categories of recipients, on a need-to-know basis to achieve such purposes:

  • our personnel (including personnel, departments or other companies of the Novartis group); 

  • our suppliers and service providers that provide services and products to us, including consultants and technical service providers, such as cloud  services and other IT services;

  • our independent agents or brokers (if any); 

  • our advisors and external lawyers, including in the context of investigations/litigation; 

  • our advisors, external lawyers and other third parties directly involved in the sale or transfer of any part of our business or its assets or directly involved in acquisition or transfer of a third-party business or asset;

  • our business partners who offer products or services jointly with us; and

  • any third party to whom we assign or novate any of our rights or obligations.

The above third parties are contractually obliged to protect the confidentiality and security of your personal data, in compliance with applicable law. 

Your personal data can also be accessed by or transferred to any national and/or international regulatory, enforcement, public body or court, where we are required to do so by applicable law or regulation or at their request. In addition, some of your personal data may need to be made available publicly following legal and regulatory obligations which we may have, such as meeting our transparency obligations.

The personal data we collect from you may also be processed, accessed or stored in a country outside the country where you are located, which may not offer the same level of protection of personal data. 

If we transfer your personal data to external companies in other jurisdictions, we will make sure to protect your personal data by applying the level of protection required under the data protection/privacy laws applicable to Novartis and acting in accordance with our policies and standards. To the extent that our processing of personal data is subject to India Digital Personal Data Protection Act, 2023 or any other country prescribing the use of protective measures for the transfer of personal data to third countries, we are only transferring personal data to countries not providing for the same level of data protection on the basis of standard contractual clauses approved by the European Commission or other alternatives prescribed by the applicable privacy laws. You may request more information or a copy of such measures by contacting us as described below (Section: ‘What are your rights and how can you exercise them’).

For intra-group transfers of personal data to our group companies, the Novartis Group has adopted Binding Corporate Rules, a system of principles, rules and tools, provided by European law, to ensure effective levels of data protection relating to transfers of personal data to Novartis affiliates outside the EEA, UK and Switzerland. Read more about the Novartis Binding Corporate Rules by clicking here.

 

How do we protect your personal data?

We have implemented appropriate technical and organizational measures to provide an adequate level of security and confidentiality for your personal data. These measures take into account the state of the art of the technology, the costs of its implementation, the nature of the data, and the risk of the processing.

The purpose thereof is to protect it against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing.

Moreover, when handling your personal data, we:

  • only collect and process personal data, which is adequate, relevant and not excessive, as required to meet the above purposes; and

  • may request you to confirm the personal data we hold about you. You are also invited to spontaneously inform us whenever there is a change in your personal circumstances so we can ensure your personal data is kept up to date.

 

How long do we store your personal data?

We will only retain personal data we may have about you for as long as we reasonably consider it necessary for achieving the purposes set out in this Privacy Notice and to comply with legal or regulatory requirements. We may continue to process your personal data until and unless you withdraw your consent.

 

What are your rights and how can you exercise them?

You may exercise the following rights under the conditions and within the limits set forth in the law:

  • Right to access information about personal data.

  • Right to correction and erasure of personal data.

  • Right of grievance redressal.

  • Right to nominate

  • Right to withdraw any consent you provided, without affecting the lawfulness of the processing prior to such withdrawal

If you want to exercise the above rights, click here.

In addition to the rights above, you may have the right, under applicable law, to file a complaint with the Data Protection Board.

How will you be informed of the changes to our Privacy Notice?

This Privacy Notice was last updated in February 2026. We invite you to visit our website (General Privacy Notice for Business Partners | Novartis India) from time to time for any updates of our Privacy Notice. Any future changes or additions to the processing of your personal data as described in this Privacy Notice will be notified to you via an update on our website (General Privacy Notice for Business Partners | Novartis India) and/or other communication channels as appropriate.