Privacy Policy

Last Updated: April 23, 2021

Our privacy policies, statements, and notices offer details about how personal data is processed by Alnylam Pharmaceuticals and its worldwide affiliates, including how information might be disclosed as well as the rights of individuals.

Website Privacy Policy

This website is owned and operated by Alnylam Pharmaceuticals, Inc. (“Alnylam”, “we”, “our” or “us”), a company established under the laws of Delaware with registered offices at 675 W Kendall Street, Cambridge, MA 02142 USA, Tel: 617.551.8200, Fax: 617.551.8101, e-mail: info@alnylam.com.

To learn more about Alnylam and its worldwide presence and how to contact Alnylam’s affiliates directly please visit our corporate website at www.alnylam.com/contact-us/.

Alnylam respects the privacy of visitors to our website. This privacy policy describes the types of personal data we collect about visitors to the website, how we use the personal data and with whom we share it. This privacy policy also describes (1) the measures we take to safeguard the personal data we collect and (2) your rights and privileges concerning our collection, use, and disclosure of your personal data.

This website privacy policy only applies to personal data collected through this website by Alnylam or by third parties acting for and on our behalf as data processors and further processed for the purposes specified herein. It does not describe the ways in which we collect or use personal data obtained offline, or the collection, use or disclosure policies or practices of any other third party collecting and processing personal data through this website independently.

For information on the collection, use and processing of personal data of Healthcare Professionals by Alnylam read the specific Privacy Notice for Healthcare Professionals (General Use)

For more information on the collection, use and processing of your personal data for electronic communications purposes, read the specific Data Privacy Notification and Consent Form for electronic communications

For more information on the collection, use and processing of your personal data for electronic communications purposes, read the specific Direct Marketing / Email Communications Notice

For more information on the collection, use and processing of your personal data collected at congresses, read the specific Data Privacy Notice for Use of Personal Data Obtained at Congresses, Symposia and other Events

For more information on the collection, use and processing of your personal data for the purpose of recruitment, read the specific Alnylam Pharmaceuticals Recruitment Privacy Notice

Personal Data Collection and Use

Alnylam respects the privacy of visitors to our website, and we recognize your need for appropriate protection and management of the personal data you share with us. You can visit our website without telling us anything about yourself. If you contact us and choose to provide your personal data, such as your name, address, telephone number or e-mail address, we will collect and use this personal data for the purposes for which you submitted it to us, namely to respond to your inquiry, to provide you with information that you have requested (such information may either relate to our products or services or consist of up-to-date disease awareness information) in the form of sending of newsletters or otherwise, to bill you for products and services you have requested, to market products and services which we think are of interest to you, or to communicate with you for other purposes which are evident from the circumstances or about which we inform you when we collect personal data from you. Such other purposes may include, from time to time, monitoring our regulatory compliance, compiling profiles and personal information about you in order to identify suitable education/awareness programs or suitable opportunities to collaborate with you.

Non-disclosure of Personal Data

We will not sell, share, or otherwise distribute your personal data to third parties except as provided in this privacy policy. We will disclose your personal data to other Alnylam affiliates worldwide that agree to treat it in accordance with this privacy policy and applicable data protection laws. Personal data will also be transferred to third parties who act for and on our behalf, for further processing in accordance with the purpose(s) for which the data were originally collected or will be otherwise be lawfully processed, such as services delivery, evaluating the usefulness of this website, marketing, data management or technical support. These third parties have contracted with us to only use personal data for the agreed upon purposes and not to sell or disclose your personal data to third parties except as required by law, as permitted by us or as stated in this privacy policy.

Personal data collected from you would also be transferred to a third party in the event that the business of this site or a part of it and the customer data connected with it is sold, assigned or transferred, in which case we would require the buyer, assignee or transferee to treat personal data in accordance with this privacy policy. Also, personal data will be disclosed to a third party if we are required to do so because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding here or abroad.

Your Privacy Rights

Whenever we process personal data concerning you, we take reasonable steps to ensure that your personal data is kept accurate and up-to date for the purposes for which it was collected.

Per applicable law, if you become aware that the personal data we maintain about you is inaccurate, incomplete, misleading, irrelevant or out of date, you have the right to access, review, update and/or rectify such personal data. You also have the right to object to or restrict the processing of your personal data if such processing is not reasonably required for a legitimate business purpose as described in this policy or in compliance with the law.

You also have the right to request that your personal data be deleted or transferred to another company, to the extent that such deletion or portability is technically possible or permitted by law. You also have the right to be made aware whether you are the subject of automated decision-making, including profiling and to object to such processing.

If you wish to contact us to receive further information regarding our use of your personal data, or if you wish to update and/or review your personal data, or if you wish to restrict and/or object to the processing of your personal data, please complete this Data Subject Request form or email us at privacy@alnylam.com and, in case you are a EU/EEA resident, please email us at EUdataprivacy@alnylam.com or as specified in the “For Additional Information” section below.

We will require evidence of your identity or to be provided with additional information before we are able to act on your request when the information, we have is insufficient to accommodate your request. We will attempt to provide any requested information or make requested changes to the extent allowable by applicable privacy laws. In any event, we will respond to you as soon as reasonably possible to advise you of the outcome of your request.

If we do not respond to your request in a timely manner, or if your request has been partially or wholly rejected or dismissed and/or you consider that your rights and freedoms with regard to the processing of your personal data have been infringed, you have the right to lodge a complaint with the applicable Supervisory Authority if you are a European resident. A list with the Supervisory Authorities in Europe and their respective contact details is available here: https://edpb.europa.eu/about-edpb/board/members_en

Data Transfers

We transfer the personal data we collect about you to third parties or within Alnylam (to other Alnylam Affiliates worldwide). Such data transfers include the transfer of personal data to countries other than the country in which the personal data was originally collected. Those countries may not have the same level of data protection as the country in which the personal data initially originated. When we transfer your personal data to such other countries, we have taken appropriate measures to ensure the protection of your personal data in accordance with this Privacy policy and all applicable data protection laws.

In particular, we ensure that third parties receiving personal data from Alnylam are contractually bound to comply with applicable data protection laws and Alnylam’s policies, including this privacy policy. We also ensure that authorized personnel handling personal data are appropriately trained and committed contractually to a duty of confidentiality.

Where cross-border data transfers occur, we ensure that an adequate level of data protection exists in the recipient country, by executing with third parties appropriate contractual arrangements for cross-border data transfers to third countries for controllers or processors as applicable.

An updated list of Alnylam’s data processors can be made available upon request by email at privacy@alnylam.com and in case you are an EU resident, by email at EUdataprivacy@alnylam.com.

Information Security

Alnylam uses commercially reasonable administrative, technical, personnel-related, and physical security measures designed to safeguard the personal data in our possession against loss, theft and unauthorized use, disclosure, or modification.

Alnylam has taken reasonable steps to ensure that appropriate technical and organizational security measures are implemented not only by Alnylam but also by data processors acting for and, on its behalf, to ensure the security of the processing of your personal data overall.

Links to Third Party Websites

As a convenience to our visitors, this website contains links to other websites that we believe offer useful information. Those links include links to websites that perform services for us. As stated in more detail in the Terms and Conditions of Use for our website, the terms of usage and other conditions of use posted on those websites, and not the policies and procedures we described here, apply to those websites. We cannot guarantee the privacy standards of websites to which we link or be responsible for the contents of sites other than this one, and this privacy policy is not intended to be applicable to any linked, non-Alnylam website.

Data Retention

Your personal data will be retained by Alnylam for the intended purposes in accordance with applicable data protection laws and company policies. Once your personal data is no longer needed, it will be promptly deleted or anonymized in accordance with Alnylam’s policies.

Cookies Notice

Periodically, some pages on this website use “cookies,” which are small files that the website places on your hard drive for identification purposes. These files are used for website registration and customization of your next time visit to our website. You should note that cookies cannot read data off of your hard drive. Your web browser may allow you to be notified when you are receiving a cookie, giving you the choice to accept it or not. You can also refuse all cookies by turning them off in your browser. By not accepting cookies, some features on our website may not fully function, and you may not be able to access certain information on this website. However, by continuing to use the site without changing settings, you are agreeing to our use of cookies as is.

If you require further information on how we use cookies in our website, visit our Cookie Policy.

Our Children’s Policy

We are committed to protecting the privacy of children. You should be aware that this website content and services are not intended for, or designed to attract, children under the age of 18. No personal data should be submitted to Alnylam through the website by visitors who are less than 18 years old. If it comes to our attention that an under 18 user of this website has volunteered personal data and/or health-related personal data, or that a healthcare professional has volunteered personal data about a patient who is identified as younger than 18, without the given or authorized consent of the holder of parental responsibility over such child, we will promptly, upon relevant notification or request, delete such personal data in accordance with our deletion policy. As noted above, we do not collect personal data unless you provided it to us by including an individual’s age.

CalOPPA Do-Not-Track Notice

Some web browsers incorporate a Do Not Track (DNT) or similar feature that signals to websites with which the browser communicates that a visitor does not want to have his/her online activity tracked. If a digital service that responds to a particular DNT signal receives the DNT signal, the browser can block that digital service from collecting certain Personal Information about the browser’s user. As of the Effective Date, not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason Alnylam does not currently respond to DNT signals. For more information about DNT signals, visit allaboutdnt.com

Privacy Policy Updates

Alnylam may, at any time, revise this privacy policy by updating this posting. If we make revisions to this privacy policy, we will update the date at the top of this privacy policy. We will continue to use and/or disclose personal data in accordance with the policy in effect at the time the data is collected, unless you have agreed to have an updated version of the privacy policy apply to the data collected while a prior version of our privacy policy was in force.

For Additional Information

If you have any questions about this privacy policy, or concerns about the practices of this website, or your dealings with this website or any privacy-related matter in general, please email us at privacy@alnylam.com or contact us in writing at:

Alnylam Pharmaceuticals, Inc
Attention: Privacy Officer
675 W Kendall Street
Cambridge, MA 02142 USA
Tel: 800.231.8685

Alnylam Canada ULC
Attention: Privacy Officer
4 Robert Speck Parkway
Suite 1522
Mississauga, Ontario L4Z 1S1

For any other questions or concerns, regardless of place of residence, please email us at info@alnylam.com or contact us in writing at:

Alnylam Pharmaceuticals, Inc
Attention: Privacy Officer
675 W Kendall Street
Cambridge, MA 02142 USA

Alnylam Canada ULC
4 Robert Speck Parkway
Suite 1522
Mississauga, Ontario L4Z 1S1
info@alnylam.com
Tel:
1-647-499-1053
1-833-673-6119
Fax:
1-613-701-4273
1-833-673-6122

Privacy Notice for Healthcare Professionals (General Use)

Alnylam Pharmaceuticals and its Affiliates (‘Alnylam’, ‘we’, ‘our’, or ‘us’) is committed to protecting your privacy, and will make all reasonable efforts to protect your personal data (“Personal Data”) in accordance with this Privacy Notice (“Notice”) which applies to the Personal Data that it collects and processes about Health Care Professionals (‘HCPs’) and employees/representatives of Healthcare Organizations (‘HCOs’).

Data Controller and Data Protection Officer (“DPO”)

Each Alnylam entity is acting as a Data Controller for the purposes of this Notice when processing your Personal Data. You can find more information on Alnylam affiliates in Europe and worldwide as well as their establishment and contact details here: http://www.alnylam.com/contact-us/.

Alnylam EU Privacy Office and the designated Data Protection Officer (DPO) are responsible for supervising and monitoring Alnylam’s compliance with applicable EU data protection laws and regulations when processing your Personal Data.

Alnylam EU Privacy Office and the appointed DPO can be contacted at EUdataprivacy@alnylam.com.

Personal Data Alnylam Collects and Source

Alnylam collects and processes Personal Data about you. The types of Personal Data Alnylam collects depend on your relationship with Alnylam as well as applicable laws and regulations and may include the following categories of personal information:

Basic personal details such as identity and contact information (e.g. your name, postal and e-mail address, telephone and mobile phone numbers); Educational and professional details such as qualifications and organizational or institutional affiliations (e.g. title, field of expertise, medical specialty, publications, interests in Alnylam products and your general treatment habits); Economic and Financial and Payments related information, where necessary.

This information may come directly from you or from public or third-party information sources (such as from third-party service providers providing health care professional data and related services).

To better understand and address your interests, and to ensure that the Personal Data that Alnylam maintains and processes about you is accurate, Alnylam may correct or add to any Personal Data you provided directly to Alnylam with Personal Data relating to you that Alnylam receives from other third-party sources.

Lawfulness of Processing

Alnylam processes Personal Data based on one or more of the following legal grounds:

In certain cases, Alnylam may ask for your consent to collect and process your Personal Data. Should you choose to provide your consent, you may later withdraw your consent without giving any reason by contacting us as described in the “How to Reach Us” section. Please note that the withdrawal of consent will not affect processing by Alnylam which has already occurred up to the date of withdrawal.

In other instances, the processing of your Personal Data may be necessary in order to comply with an applicable law or regulation or for the performance of a contract to which you are subject. You may not be able to opt-out of this processing, or your choice to opt-out may impact our ability to perform a contractual obligation otherwise owed to you.

In still other instances, Alnylam may process your Personal Data based on Alnylam’s legitimate interests in communicating with you about our products and services, about scientific research and/or about educational opportunities. You have the right to opt-out of all such processing of your Personal Data. You may do so by contacting us as described in the “How to Reach Us” section.

How Alnylam Uses your Personal Data

Alnylam processes Personal Data about you for one or more of the following purposes:

To perform Alnylam’s obligations under a contract to which you are a party;
To comply with applicable laws or regulations;
To publicly disclose any transfers of value made to you, as a Health Care Professional, as required by law or in order to comply with applicable industry standards;
To provide you with corporate information on Alnylam;
To provide you with promotional information on Alnylam branded products and services and to carry out promotional activities to you, subject to other applicable regulatory provisions (e.g. e-Privacy Directive);
To provide to you, on your request, medical and scientific information and updates;
To handle adverse events reports or quality complaints;
To send to you invitations to promotional or scientific events e.g. webinars or send you CME invitations;
To invite you to share with Alnylam your professional insights, to participate in surveys and market research activities; and/or
To collect and analyze your interests and professional experiences to improve our profile of you as an HCP, including by inferring insights, to provide you with targeted advertising e.g. scientific updates and further enhance the business relationship we have with you (this profile may include your age and gender, medical specialty, prescription habits and others).

The information provided above will be shared via Alnylam’s e-communications channels e.g. by sending you customized or non-customized email and internet communications or to contact you at your office or mobile telephone number (by call or SMS messages), by fax, by the post or through Alnylam’s social media accounts and specific content websites.

Alnylam shall use your Personal Data only for the purposes specified in this section; processing of your Personal Data for any other purpose will be carried out only through prior notification and your specific consent to processing such Personal Data for any possible secondary use or for further purposes.

With Whom Alnylam Shares your Personal Data

Alnylam may transmit Personal Data about you to other Alnylam affiliates worldwide. These affiliates may in turn transmit Personal Data about you to other Alnylam affiliates. Alnylam may also contract with third parties (third party service providers) to perform wholly or partly activities or functions related to the purposes specified above on behalf of Alnylam that involve the use of Personal Data about you. In such cases, Alnylam will require these third parties to comply with applicable data protection laws or regulations and Alnylam company policies to protect the confidentiality and security of the Personal Data that is shared with them. These third parties will be required to agree that they will not use or disclose Personal Data about you except as necessary to provide services to us or perform services on our behalf, or as necessary to comply with applicable laws or regulations.

Moreover, all of Alnylam’s affiliates and third-party data processors acting for and on behalf of Alnylam are required to treat Personal Data in a manner consistent with applicable data protection laws and internal company policies including this Notice.

Some of Alnylam's group companies and/or third-party service providers may be located in countries whose laws may not afford your Personal Data the same level of data protection as the one afforded inside your country. Where your Personal Data will be transferred to third countries, Alnylam will ensure that all adequate safeguards are in place and that all applicable laws and regulations are complied with in connection with such cross-border data transfers; in particular by adopting in its contractual arrangements for cross-border data transfers for Controllers and Processors as well as by implementing appropriate technical and organizational security measures to ensure the security of the processing.

In addition, for the aforementioned purposes, Alnylam transfers some of your Personal Data, according to a strict criterion of relevance, to authorities as well as to other external governmental bodies, having the power to execute checks and investigations towards Alnylam in fulfilment of legal obligations or regulations. These authorities and institutions will act as independent data controllers of their respective processing operations.

To obtain a list of Alnylam’s data processors and categories of data controllers as well as additional information regarding the safeguards Alnylam has in place for cross-border transfers of Personal Data, please contact us using the information provided in the “How to Reach Us” section.

How Alnylam Protects your Personal Data

Alnylam will take reasonable and appropriate physical, administrative and technical safeguards to protect the processing of your Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction. In this perspective, the data may be used only by Alnylam’s personnel who need it because of their job or hierarchical position, with confidentiality obligations, which have been assigned a specific role and which have been given appropriate operating instructions.

Your Rights and How to Exercise Them

Individuals in the EU have certain data subject rights which may be subject to limitations and/or restrictions. These rights include the right to: (i) request access to and rectification or erasure of their Personal Data; (ii) restrict processing, or to object to processing of their Personal Data; and (iii) the right to data portability. If you wish to exercise one of the above-mentioned rights, please refer to the “How to Reach Us” section below.

Individuals in Canada have the right, upon request, to be informed of the existence, use, and disclosure of his or her personal information and to be given access to that information. An individual in Canada also has the right to challenge the accuracy and completeness of the information and have it amended as appropriate. These rights are subject to specific and limited exceptions. Individuals in Canada also have the right to challenge Alnylam’s compliance with applicable Canadian privacy legislation, by contacting Alnylam directly.

You also have the right to ask Alnylam not to process your Personal Data for marketing purposes. Alnylam will usually inform you (before collecting your data) if it intends to use your data for such purposes or if it intends to disclose your information to any third party for such purposes. You can exercise the right to prevent such processing by informing Alnylam at any time that you do not wish to receive such marketing. Where you wish to exercise this right please refer to the “How to Reach Us” section below.

If you do not receive a (timely) response from Alnylam or if you are not satisfied with our response to you, you also have the right to lodge a complaint about the processing of your Personal Data with the appropriate national data protection supervisory authority if you are resident of the EU or Canada. A list of the national data protection supervisory authorities in Europe can be found here: https://edpb.europa.eu/about-edpb/board/members_en.

How long Alnylam Retains Personal Data

Personal data will only be stored as long as necessary to fulfill the purposes and respective obligations related to such data, for which it was collected, subject to local laws and regulations and legitimate business needs in accordance with Alnylam internal policies.

However, as these purposes and obligations vary from one processing situation to another, Alnylam provides more information on such storage periods in the topic specific privacy notices. Once Personal Data is no longer necessary, Alnylam deletes it or anonymizes it as soon as possible.

For marketing purposes, including any profiling for direct marketing, we will keep your personal data for as long as you want to receive marketing from us. If you decide to opt-out of or withdraw your consent to our marketing, we will no longer use your personal data for this purpose and we will suspend your HCP account for marketing purposes. If the data is not needed for some other purpose (e.g. to carry out our customer relationship), we will delete the data without undue delay or anonymize it as practically possible.

How to Reach Us

For further details on how Alnylam collects and processes your Personal Data please read the relevant section in this Privacy Policy.

You may also reach us via email us at privacy@alnylam.com or contact us in writing at:

Alnylam Pharmaceuticals, Inc
Attention: Privacy Officer
675 W Kendall Street
Cambridge, MA 02142 USA
Tel: 844.543.8355

Alnylam Canada ULC
Attention: Privacy Officer
4 Robert Speck Parkway
Suite 1522
Mississauga, Ontario L4Z 1S1

Fair Market Value and Transfers of Value

What personal data do we process?

In some situations, we may seek to enter into a separate agreement or relationship with you such as if you participate in a special program or activity. Any Personal Data provided by you and/or collected by Alnylam including but not limited to your name and surname, professional contact details, professional and/or academic qualifications, curriculum vitae, financial details and payments made will be processed for the purposes of evaluating any potential collaboration with Alnylam in those initiatives of your interest and for any future collaborations including payment of honoraria when applicable. Alnylam collects most of this personal data directly from you when you provide us with your curriculum vitae. Where permitted, we may also collect information about you from publicly available sources to evaluate compliance with anti-bribery and corruption laws. This information is only processed where relevant and necessary to evaluate your background properly and to meet our commitment to deal only with valid and ethical business partners.

For what purpose do we Process your personal data?

Managing our contractual relationship with you including payment of honoraria and taxes and monitoring such payments for compliance with our internal procedures relating to engagements with healthcare professionals and experts; management of your travel and accommodation arrangements; submission of records to public authorities under any applicable law; and for our own internal evaluation and business overview purposes.
Complying with openness and transparency principles and legislation that are key for the pharmaceutical industry. These principles and/or provisions of the law aim to increase the understanding about collaborations between pharmaceutical companies and healthcare organizations and its co-workers. As part of this goal, transfers of value, such as consultancy fees from pharmaceutical companies to healthcare professionals and healthcare organizations are publicly disclosed on an annual basis. The information remains publicly available for a limited period; in Europe, the retention period is set to three years calculated from the date on which the information was first published. If under local law or other regulations of the country where you reside in, we need your consent for this purpose and should you disagree with your information being shared individually, we would only publish it in an aggregated manner.

What is the legal basis for processing your personal data?

Necessary to fulfil the contract that you are going to enter into, or have entered into, with us
Consent for reporting transfers of value, which you can withdraw at any time without affecting the lawfulness of processing based on consent before its withdrawal

Where is your personal data transferred?

Alnylam might transfer your personal data to the affiliates of the Alnylam Group of Companies worldwide and any other third parties and collaborators located in countries that might not provide an adequate level of data protection. However, Alnylam will implement the adequate safeguards to protect the confidentiality of your personal data such as the signature of the Standard Contractual Clauses approved by the European Commission and any other legal mechanisms required by applicable legislation. Alnylam might also share your data with the competent authorities in your country and in other countries for Alnylam’s compliance with any legal obligations as required by applicable law.

For how long do we keep your personal data?

Your data will be kept by Alnylam for the retention periods defined by applicable legislation and as long as necessary for achieving the data processing purpose.

What are your rights and how you can exercise them?

Please, note that you can exercise your data privacy rights such as the rights of access, rectification, cancellation, opposition, deletion or obtention of a copy, please complete this Data Subject Request form or email us at privacy@alnylam.com.

In case you have any questions about how your personal data is processed, please contact us in the first instance and we will take appropriate steps to address your concern. However, please note that you have the right to lodge a complaint with the applicable Supervisory Authority if you are a European Economic Area (EEA) or United Kingdom (UK) resident. A list with the Supervisory Authorities in the EEA and their contact details is available here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en and UK residents can contact the Information Commissioner’s Office at: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, +0303 123 1113 (or +44 1625 545745 if calling from outside the UK).

Last update, May 2024

Data Privacy Notice and Consent Form for Use of Your Personal Data for Electronic Communications Purposes

Data Controller

Alnylam Pharmaceuticals Inc. in the US (“Alnylam”) will act as a data controller and will process your personal data, as specified below, by determining purposes and means of its processing.

Types of Personal Data

Alnylam will process the following Personal Data as applicable: Your contact details, including your name, address, e-mail address, country (altogether “Personal Data”).

Purposes of Use of your Personal Data

Alnylam shall use, process and store your Personal Data in order to send you non-customized email communications in relation to Disease Awareness information in the disease area(s) of your choice and for no other purposes. Any other purpose will require your specific consent.

Scope of Data Flows

For the above-mentioned purposes, your Personal Data will be collected by Alnylam, which is the US legally incorporated entity, and be transmitted to companies of the same group, with the adoption of adequate technical and organizational measures. Alnylam will forward the same data to third parties (individuals and/or companies) acting on its behalf as data processors, including Salesforce Cloud Inc as data storage, which will also be established outside of originating countries.

The list of Data Processors can be requested by sending an email to privacy@alnylam.com.

The circulation of your Personal Data, considering the dissemination of the same, will reside on US servers. In this case, Alnylam will ensure that appropriate safeguards are in place to legitimize the transmission, such as the adoption of contractual clauses approved by the EU Commission or the data protection national supervisory authority.

Free Provision of Data and Free Consent

You declare that you are eighteen (18) years old or above and legally competent.

You are free to provide such data or your consent to the relevant processing, and your refusal will solely mean that Alnylam will not be authorized to collect and use your Personal Data for sending electronic communications to you.

Processing Mechanisms

Personal Data above will be processed both electronically and manually.

Data retention

Your Personal Data will be reviewed after a 5-year period to ensure your active participation in the receipt of information about your selected disease area(s) of interest. If you would like your data to be deleted prior to the 5-year period, please contact privacy@alnylam.com.

Exercise of Your rights

You have the right to unsubscribe from receipt of emails in relation to Disease Awareness information in the disease areas of your choice, amend your contact details and other personal data or change your disease areas choice at any time by clicking the unsubscribe link included in future email communications.

You can at any time request to be informed about the personal data Alnylam holds about you, access your personal data or ask Alnylam to rectify, erase or block such personal data. For these purposes and for any other questions, please contact Alnylam at the following email address: privacy@alnylam.com; or by mail to Alnylam’s address:

Alnylam Pharmaceuticals, Inc.
Attention Privacy Office
675 W Kendall Street
Cambridge, MA 02142 USA

You can at any time revoke your consent in writing and submit via email to the address specified above, without having to provide any reason. You may also complete this Data Subject Request form.

Residents of the EU/EEA, in case your data protection-related requests are not handled in a timely and appropriate manner, you have the right to recourse to the competent data protection supervisory authority by lodging a relevant complaint.

To concretely exercise your data protection rights under applicable law in respect to third-party companies that provide services to Alnylam, you can at any time request the list of such companies by sending an email to privacy@alnylam.com.

Consent Statement

I have read and understood the content of the above notification and by completing the subscription form to receive updates I expressly consent to the processing of my personal data by Alnylam in the US as well as to the transfer of such data to entities established in the US, in accordance with the terms and mechanisms specified above, taking into consideration that my consent can be withdrawn at any time.

Direct Marketing / Email Communications Notice

You can elect to receive email updates about developments regarding Alnylam’s products and/or services or about health-related specific topics (e.g. to receive email updates about hereditary ATTR amyloidosis from Alnylam) by completing the relevant electronic form on our website.

In the event of direct marketing of our products and/or services, with any and all means, we will provide you with a method to opt out of or opt-in in receiving further marketing materials as required by law.

If you decide, at any later time, that you no longer wish to receive such email communications from us, you can unsubscribe to any such contact list by using the relevant “Unsubscribe” link within the respective electronic communications channel, or by sending us an email entitled “Unsubscribe from email updates about hATTR amyloidosis” at privacy@alnylam.com.

Data Privacy Notice for Use of Personal Data Obtained at Congresses, Symposia and other Events

At a congress in which Alnylam participates as a sponsor and/or exhibitor, at an Alnylam organized symposia or at any other event, Alnylam authorized personnel may request your consent to scan your badge when entering the event venue, including when attending Alnylam sponsored sessions or when visiting Alnylam’s exhibitor booth.

By allowing Alnylam to scan your badge in the above circumstances, you express your consent for Alnylam and its Affiliates worldwide (collectively referred to as “Alnylam”) to receiving your Personal Data (such as name, surname, address, e-mail address, phone numbers, medical specialty), which you voluntarily provided to the congress organizer, when you registered for the venue, and further processing it for marketing and compliance purposes, in accordance with applicable data protection laws, industry codes and Alnylam’s policies.

We will also further process your personal data, by relying on Alnylam’s legitimate business interests to comply with industry codes and standards and to communicate with you to provide you with information about Alnylam’s medicinal products and services, about medical and scientific research updates and/or about educational opportunities, that might be of interest to you, as well as to invite you to relevant promotional activities as further described in the specific Privacy Notice for Healthcare Professionals (General Use).

Scanning of your badge is voluntary; you are not required to agree to it and it will not affect your participation to the event or any specific session. If you choose at the time to consent to the scanning of your badge, you are able to withdraw your consent at any later time, without giving any reason, by contacting us at privacy@alnylam.com or is you are a resident of Europe at EUdataprivacy@alnylam.com.

Candidate Privacy Notice

This Privacy Notice was last updated on March 18th, 2024.

"Alnylam " means Alnylam Pharmaceuticals Inc. in the United States together with its subsidiaries and affiliates worldwide. Alnylam is also referred to in this Notice as "we", "us" or "our".

Data Controller

The data controller decides why and how to process your personal data. However, other affiliates of the Alnylam Group of Companies may also access and process your personal data as described in this notice. For each activity, Alnylam and its affiliates worldwide will act as controller together or jointly regarding the processing of your data.

Purposes for the Collection and Processing of Your Personal Data

The Notice provides you with ("you" or "your") information regarding how we handle, process and protect your personal data, in connection with our recruiting process as well as informing you of your data privacy rights related to our processing of your personal data. Please read this Notice carefully prior to providing your personal data to Alnylam.

As used in this Privacy Notice, “personal data" means any information related to job applicants and potential candidates for employment with Alnylam, either submitted as part of an online application platform and/or through alternative recruitment channels (e.g., via professional social media channels, professional recruiting firms or thorough our Employee Referral Scheme).

An updated list of recruiting agencies and other third-party sources, providing Alnylam personal data on job applicants and potential candidates, can be available to you upon submission of a relevant request via e-mail at privacy@alnylam.com.

We will process your personal data in accordance with this Privacy Notice, and for the uses and purposes that are compatible with the management of your candidacy for the positions of your interest and in the context of our selection processes.

Legal Basis for Processing

In some countries a legal basis for the processing of your personal data might not be required (e.g. United States, Hong Kong).

In those countries and states where a legal basis is required for the processing of your personal data, the legal basis shall be determined based on the type of data we process about you and the uses for the processing of your personal data. In those cases the most suitable legal basis in relation to recruitment will be one of the following:

Legitimate interests - the processing is necessary for our legitimate interests or the legitimate interests of a third party e.g., to process and assess your application for employment with us.
Consent – only in those cases where consent is strictly necessary, such as in connection with the processing of sensitive data that you voluntarily provide to us in connection with inclusion and diversity purposes. Please note that this information will be processed by Alnylam in an aggregated form exclusively. Also, when you have given your consent for the processing to take place when requested explicitly e.g., contacting a referee or for pre-employment screening where applicable.

Where we have relied on your consent as the legal basis for processing your personal data, you have the right to withdraw your consent at any time. For further information on how to withdraw your consent please see the “Your Data Privacy Rights" section.

What Personal Data We Collect About You

The types of personal data that we request from you and the ways that we process it are determined by the requirements of the country in which the position is located, and not the country in which you reside. Should you apply to more than one location or should the role to which you apply be available in more than one country, the types of personal data we request from you and the ways that we process it are determined by the requirements of all the countries in which the position is located. We usually collect personal data directly from you and/or through our recruitment portal when you apply for a role with us, such as but not limited to your name, address, contact information, ID and passport number, professional and academic qualifications, certifications, test results obtained during the process and other relevant information from your Curriculum Vitae (CV) and in the context of the selection process. Through your application you agree that we may also collect personal data about you from third parties, such as the referees provided by you and prior employers. We may also collect and process your personal data from professional portals where you have made available your personal data for recruitment purposes e.g., LinkedIn. Finally, we collect and store login and password details for your online account.

We encourage you to exclude any sensitive personal data and those that is not relevant for selection purposes in your application including in your cover letter.

How We Use your Personal Data

We collect and use your personal data in connection with your application for the positions of your interest and the management of your selection process Our main processing activities consists on the following:

identifying and evaluating candidates for potential employment, as well as for future roles that may become available;
supporting and processing your application, for example, so we can assess your ability to meet the requirements for an specific position;
to verify references and professional qualifications provided by applicants;
evaluating and assessing the results of interviews;
record keeping in relation to recruiting and hiring;
carrying out pre-employment screening, that is appropriate and proportionate to the nature of the job function, subject to specific local regulations;
compliance with our legal obligations in connection with the applicable legislation locally;
Conducting the relevant background checks and other due diligence processes as permitted by applicable legislation;
for the legal defense of the company to the extent authorized or permitted by law; or
Relevant contact by us or through our recruitment partners via the details you have provided us in relation to your application.

We may also analyse your personal data or aggregated/anonymised data for diversity and inclusion purposes, to improve our recruitment and hiring process and augment our ability to attract successful candidates.

Use of Artificial Intelligence and Similar Technologies

Alnylam is an organization that is committed to the compliance with the applicable legislation and has developed internal policies for the responsible use of artificial intelligence technologies “AI").

These policies involve the application of principles for the responsible use of AI, the implementation of the adequate organizational and information security measures and to enter into agreements with third parties and collaborators that guarantee the protection of the confidentiality of your personal data.

Alnylam might use technologies that qualify as AI for recruiting purposes and increasing our efficiency for the selection of the potential candidates for recruiters’ review when candidates submit any application through the Alnylam recruitment portal.

These technologies might also be used to match the candidate profile within the recruitment portal with potential professional opportunities and facilitate these operations.

Notwithstanding, these algorithms will not have the level of autonomy to make any decisions and such technologies are not used by Alnylam to make any decisions about the potential selection of candidates without human intervention. Any decisions regarding the selection of candidates for Alnylam positions are made by our recruitment team.

Your aggregated information might be used by Alnylam and their third-party vendors for machine learning purposes and for the continuous improvement of our recruiting processes. Your personal data will not be used for these purposes.

You can find further information on how to exercise your data privacy rights such as your right to object or request human intervention in the Section “Your Data Privacy Rights".

Automated Decision Making

We do not make recruiting or hiring decisions based solely on automated decision-making.

Who We Share Your Personal Data With

Alnylam might share your personal data with their affiliates worldwide and their third-party vendors and collaborators in the context of their global operations as follows:

With the affiliates of the Alnylam Group of Companies worldwide - We restrict access to your personal data to people within Alnylam who “need to know" that information, e.g. the individuals who will process your job application and manage the recruitment process working in the country where the position for which you are applying is based, as well as by recruiters and interviewers working in different countries within the Alnylam global organization.
With our third-party vendors and collaborators- Alnylam shares your personal data with trusted third-party providers and collaborators, in order to manage recruitment, notably to conduct screening and verification of your application and the information you provide, e.g., academic/professional qualifications, where necessary and applicable.

Generally, Alnylam will only disclose your personal data to other third parties:

when required to do so by law;
based on a court order, in response to a legitimate request for assistance by the competent authorities and public bodies or other law enforcement agency; or
for the legal defense of the company or to seek legal advice from Alnylam’s external lawyers or in connection with litigation.

International Data Transfers

We may transfer any personal data we collect about you to the affiliates of the Alnylam Group of Companies or to third parties worldwide. Such data transfers include the transfer of personal data outside to your country of residence. Those countries may not have an adequate level of data protection Notwithstanding, when we transfer your personal data to such other countries, we have taken appropriate measures to ensure the protection of the confidentiality of your personal data in accordance with this privacy policy and all applicable data protection laws.

Where cross-border data transfers occur, we implement the correspondent legal mechanism, such as the signature of the Standard Contractual Clauses approved by the European Commission and other applicable mechanisms recognized by the applicable legislation to cover these cross-border data transfers.

An updated list of Alnylam’s data processors can be made available upon request by email at privacy@alnylam.com.

Data Retention

If you accept an offer of employment by Alnylam, any relevant personal data collected during the selection process will become part of your employee records and will be retained in accordance with specific country requirements and internal policies and procedures.

If your application is unsuccessful, we will hold your personal data on file for the purpose of system administration and reporting purposes and to consider you for potential future roles and employment opportunities. This personal data will be kept for the maximum retention period defined by the applicable law in your country of residence.

At the end of such period, we may ask you to renew your registration in our recruitment platform or confirm the retention of your personal data by Alnylam for an additional period of time and provide you an opportunity to update your personal data. If you accept, the retention period shall be extended, otherwise your personal data will be safely and permanently deleted from our records, in accordance with our data retention policy and schedule.

Your Data Privacy Rights

You can exercise your data privacy rights regarding the personal data that we process about you (this will depend on the jurisdiction where you reside and the legal basis that we use). Please note that the exercise of your data privacy rights might be restricted according to the applicable laws. We will respond to your request accordingly and provide further clarification in case your request is subject to any of these limitations.

Please note that your rights might vary depending on your jurisdiction.

You may have the following data privacy rights:

Right of Access – Access to the personal data we hold about you, free of charge in most cases.
Right to Rectification – The correction of your personal data when incorrect, out of date or incomplete.
Right to Erasure – The deletion of the personal data we hold about you, in specific circumstances; for example, when you withdraw consent or object, and we have no legitimate overriding interest, or once the purpose for which we hold the personal data has come to an end.
Right to Data Portability – A computer file in a common format (CSV or similar) containing the personal data that you have previously provided to us, and the right to have your personal data transferred to another entity where this is technically possible.
Right to object to or restrict processing – Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made.
Right to Object – That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances.
Rights in relation to automatic decision making and profiling – Review of any decision made based solely on automatic processing of your personal data (so where no human has yet reviewed the outcome and criteria for the decision).
Rights in relation to whether a business has disclosed personal data to any third parties for the third parties’ direct marketing purposes. However, as stated in our Privacy Policy, Alnylam will not sell or share your personal data with anyone other than our research and/or development partners or agents and will not sell or share your personal data with anyone for their direct marketing purposes.

If you would like to exercise any of the above rights or make a request to access, review, or correct the personal data we have collected and hold about you, or to receive further information on how we process your personal data, please contact us at privacy@alnylam.com.

If you wish to contact us to receive further information regarding our use of your personal data, or if you wish to access your personal data, please complete this Data Subject Request form, email us at privacy@alnylam.com.

For residents in California: please contact us at privacy@alnylam.com or by phone to +1 800.231.8685

Children’s Policy

We are committed to protecting the privacy of children. You should be aware that our recruitment site is not intended for, or designed to attract, children under the age of 18. No information should be submitted to Alnylam through the web site by visitors who are less than 18 years old. As noted above, we do not collect personally identifiable information unless you provided it to us including an individual’s age.

Cookies and other tracking technologies

When you visit our websites, we may store or retrieve information on your browser, mostly in the form of cookies. You can find out more about cookies and how to control them in the information below.

By accepting the cookie banner on our websites you accept the use of cookies in accordance with our Cookie Policy. In particular, you accept the use of Third-Party Cookies for the purposes described in our Cookie Policy.

If you do not accept the use of these cookies please disable them following the instructions in this Cookie Policy, for instance by changing your browser settings so that cookies from this website cannot be placed on your computer or mobile device.

Alnylam does not track its users over time and across third party websites and therefore does not respond to Do Not Track (DNT) signals. Alnylam does not authorize third parties to collect personal data directly from our users on our web site, such as through the use of third-party advertisements.

You can learn more about our use of Cookies and other tracking technologies by reading our Privacy Policy as well as our Cookie Policy.

Contact Us

If you have any enquires or if you would like to contact us about our processing of your personal data, including to exercise your data privacy rights as outlined in the Section “ Your Data Privacy Rights", please contact us at privacy@alnylam.com.

Additional Privacy Rights

If you have any concerns or complaints regarding the processing of your personal data, or our compliance with the applicable data privacy legislation , you can contact Alnylam’s Data Protection Officer at privacy@alnylam.com.

The residents in the European Economic Area (EEA) also have the right to lodge a complaint with the with the competent data protection authority whose contact details are available at the following link: https://edpb.europa.eu/about-edpb/board/members_en.

Changes to this Notice

Alnylam reserves the right to modify this Privacy Notice. We will publish any changes made to our Privacy Notice on this page. Please check this page regularly to see an updated version of this Notice.

Social Media Monitoring Privacy Notice

Scope

Alnylam Switzerland GmbH , together with its Affiliates (‘Alnylam’, ‘we’, ‘our’, or ‘us’) wants to understand how social media users discuss about diseases and medicinal products and services relevant to the Alnylam brand, so that we can take into account the needs of the general public in our communications and business plans. From time to time, we analyse social media activity related to our brand and monitor the use of our own social media channels. The conclusions drawn from the analysis will help shape Alnylam’s business plans and communication strategy. Alnylam is strongly committed to protecting your privacy, and will make all reasonable efforts to protect your personal data (“Personal Data”) in accordance with applicable data protection laws and regulations and this Privacy Notice (the “Notice”).

Data Controller and Data Protection Officer (“DPO”)

Alnylam is the Data Controller for the processing of Your Personal Data for the purposes of this Notice. You can find more information on Alnylam affiliates in Europe and worldwide as well as their establishment and contact details here: http://www.alnylam.com/contact-us/

Our Alnylam EU Privacy Office and the designated Data Protection Officer (DPO) can be contacted by email at: eudataprivacy@alnylam.com

Personal Data Alnylam Collects and Source

We monitor publicly available media including social media data, using commercially available media monitoring tools. The data we obtain from monitoring efforts is used to better understand public discussions and needs regarding diseases and medicinal products and services relevant to Alnylam brand.

We use an external service provider to process and analyse public social media data (social media monitoring activities) on our behalf and according to our documented instructions, in compliance with applicable laws and regulations.

To carry out the processing, Alnylam may use for example, commercially available social media monitoring tools such as the one provided by Sprinklr, Inc. a US-based company with offices at 29 West 35th Street, New York, NY 10001, USA; please review Sprinklr’s privacy policy to understand how Sprinklr collects and processes your personal data: https://www.sprinklr.com/privacy

Processed data may include the following categories of personal information:

Identification data (name, username, user identification and geographical area);
personal characteristics (age, gender and family status);
consumer habits;
hobbies and interests;
professional and educational background;
pictures and videos;
any other information published on a website that is analysed or on a third-party platform.

The external provider collects, analyses and monitors through media monitoring tools data from public posts (conversation streams and publicly available opinions, statements or other interactions and content) by social media users on different social media channels (such as Instagram and Facebook), and tracks different online sources including forums, blogs and online news websites.

The data gathered through the media monitoring tools may include social media handles and content from posts which are exclusively made publicly available by the social media users themselves.

The data collected by the service provider via the media monitoring tools is used to create insight reports, which are then shared with Alnylam. These reports aim to gain insights in conversation trends over a specified period of time and not to identify specific individuals.

Insight reports will be anonymized and will not include any personal data gathered from media monitoring. However, individual quotes with personal information may be captured as examples and used to describe the general attitude towards Alnylam in social media and/or for monitoring/audit purposes. These quotes will be limited to those of individuals who publish posts about the Alnylam in their professional capacity (e.g. HCPs or representatives of patients’ associations) or those of patients’ ambassadors.

We do not actively collect sensitive personal data, but we may process such data in monitoring social media, where such data is included in social media posts solely for purposes linked to safety and quality surveillance and reporting as required by applicable laws and regulations.

We have set up strict limitations on the topics we monitor and have ensured that our personnel, when accessing and using the external’s provider’s database, is bound by clearly documented instructions and confidentiality obligations.

Lawfulness of Processing

The lawful basis for processing your Personal Data is Alnylam’s legitimate interests to protect its assets and its brand on social media, by gaining insights in conversation trends over a specified period, to the extent these interests are not outweighed by the rights and freedoms of the data subjects concerned.

To the extent that we will need to collect regular or sensitive data for safety surveillance and reporting purposes, as mentioned above, the lawful basis for that processing is that:

the processing is necessary for compliance with a legal obligation to which the data controller (Alnylam) is subject;
the processing relates to personal data which are manifestly made public by the data subject; and
the processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of Union or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject, in particular professional secrecy;

Purpose(s) of Processing

Alnylam processes Personal Data for the following purposes:

To identify and assess what is being said about Alnylam and its products and services on publicly accessible social media content to understand sentiment, intent, mood and market trends and the public’s needs and thereby improve our services and take into account the needs of the general public in our communications; and
To measure the effectiveness of Alnylam’s communications strategy.

Alnylam shall use the Personal Data only for the purposes specified in this section.

Recipients of Your Personal Data

Any Personal Data retrieved from media monitoring tools will be retained and stored on the external service provider’s IT systems and applications and will not be downloaded into Alnylam IT systems.

Insight reports and/or Personal Data may be shared internally with other Alnylam affiliates worldwide. Insight reports will be anonymized and will not capture any personal data gathered from media monitoring. Anonymized reports will be stored on a secure collaborative platform which is owned and managed by our external service provider.

Where insight reports and/or personal data may be shared with recipients located in third countries, Alnylam will ensure that all appropriate safeguards are in place and that all applicable laws and regulations are complied with in connection with such cross-border data transfers; in the absence of any adequacy decision, Alnylam relies, in particular, on the execution of the appropriate EU standard contractual clauses for data controllers and processors, as adopted by the European Commission, to ensure an adequate or substantially equivalent level of data protection when transferring personal data to other member companies of the Alnylam Group (including in the United States and the United Kingdom), as well as with respect to data transfers made to service providers, acting on behalf of and for Alnylam and other Alnylam partners located in third countries. In adopting the appropriate safeguards, Alnylam will also implement any supplementary measures that may be required by legislative or regulatory authorities, or that may be deemed necessary, to ensure an adequate or substantially equivalent level of data protection with respect to the transferred data, taking into account the factual circumstances of the transfer in question.

Retention

Personal data will only be stored as long as necessary to fulfil the purposes and respective obligations related to such data, for which it was collected, subject to local laws and regulations and legitimate business needs in accordance with Alnylam internal policies.

The external service provider will retain identifiable personal information that is downloaded from search monitoring tools in order to compile the insight reports.

Data gathered by our external service provider will be stored according to the service provider’s retention policies and also to Alnylam’s policies and documented instructions.

All downloaded identifiable data will be reviewed on an annual basis and deleted if no longer serves the original purpose of collection and processing. Τhe external provider will delete the results of the searches, as well as automatic backups after the end of the respective contract with Alnylam.

Produced insight reports will not include any personal data. Insight reports will be stored for a maximum of five years and will then be destroyed/deleted.

Automated decision-making

Data may have been subject to automated decision-making by the media monitoring tools to identify it as falling within a particular search description.

How Alnylam protects your Personal Data

Alnylam will take reasonable and appropriate physical, administrative and technical safeguards to protect the processing of the Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction. In this perspective, the data may be used only by Alnylam’s personnel who need it because of their job or hierarchical position, with confidentiality obligations, which have been assigned a specific role and which have been given appropriate operating instructions.

Your Rights and how to exercise them

Individuals in the EU have certain data subject rights which may be subject to limitations and/or restrictions:

You have the right to object to the processing of your personal data.
You have the right to request information about how your personal data is processed, and to request a copy of that personal data.
You have the right to request that any inaccuracies in your personal data are rectified without delay.
You have the right to request that any incomplete personal data is completed, including by means of a supplementary statement.
You have the right to request that your personal data is erased if there is no longer a justification for them to be processed.
You have the right in certain circumstances (for example, where accuracy is contested) to request that the processing of your personal data is restricted.
You have the right to object to the processing of your personal data where it is processed for direct marketing purposes.

If you wish to exercise one of the above-mentioned rights, please refer to the “How to Reach Us” section below.

If you do not receive a (timely) response from Alnylam or if you are not satisfied with our response to you, you also have the right to lodge a complaint about the processing of your Personal Data with the appropriate national data protection supervisory authority; a list of the national data protection supervisory authorities in Europe can be found here: https://edpb.europa.eu/about-edpb/board/members_en

Further information and Contact details

For additional information on how Alnylam collects and processes your Personal Data please visit our Privacy website available here: https://alnylampolicies.com/

The contact details of the data controller are:
Alnylam Switzerland GmbH:
Grafenauweg 4, 6300 Zug, Switzerland
info@alnylam.com
+41 41 561 3500

To exercise your rights or to request additional information, you may contact our EU Privacy Office and Data Protection Officer by email at eudataprivacy@alnylam.com or in writing at the address below:

EU Privacy Office:
ALNYLAM Switzerland GmbH
Attention: Legal department
Address: Grafenauweg 4,6300 Zug, Switzerland
Tel: +41 41 561 3500

Please note that you can also fill out this data subject request form.

Complaints

If you consider that your personal data has been misused or mishandled, you may also submit a complaint to the Federal Data Protection and Information Commissioner (FDPIC); the FDPIC can be contacted at:

Federal Data Protection and Information Commissioner:
Feldeggweg 1, CH – 3003, Berne
+41 (0)58 462 43 95
info@edoeb.admin.ch

Any complaint to the Federal Data Protection and Information Commissioner is without prejudice to your right to seek redress through the courts.

You may also contact, if you are an EU/EEA resident, the competent data protection authority of your country of residence or place of work; Information and contact details of the competent authorities is available on the EDPB’s website at Members | European Data Protection Board (europa.eu).