INFORMATION ON THE PROCESSING OF PERSONAL DATA
I. INTRODUCTION
II. NOTICE
III. PERSONAL DATA ADMINISTER
IV. PERSONAL DATA PROTECTION OFFICER
V. PERSONAL DATA
VI. HOW WE COLLECT PERSONAL DATA
VII. HOW WE PROCESS PERSONAL DATA
VIII. PURPOSE AND LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
IX. HOW WE DISCLOSE PERSONAL DATA
X. RIGHT OF INDIVIDUALS
XI. PERSONAL DATA PROTECTION
XII. STORAGE PERIOD OF PERSONAL DATA
XIII. TRANSFER OF DATA ACROSS BORDERS
XIV. COOKIES
XV. NON-ETHIANS
XVI. SUBMISSION OF A COMPLAINT TO A REGULATORY AUTHORITY
I. INTRODUCTION
This “Personal Data Processing Notice” (Notice) describes how we work with your Personal Data, how we protect your Personal Data, and the choices you can make with respect to your Personal Data.
II. INFORMATION OBLIGATION
1. This document serves to fulfill the information obligation in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (RODO).
2. We clarify that in accordance with Article 13 of the RODO, information is provided when data is collected from the data subject.
3. We clarify that in accordance with Article 14 of the RODO, information is provided when personal data is obtained by means other than from the data subject.
III. ADMINISTRATOR OF PERSONAL DATA
1. The administrator of your Personal Data, that is, the entity responsible for the collection, use and disclosure of your Personal Data, is:
FARMAK INTERNATIONAL Sp. z o.o. with its registered office in Warsaw (00-133)at Al. Jana Pawła II 22, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, XII Economic Division of the National Court Register under KRS number: 0000589765, NIP: 7010505403, REGON: 362449685.
2. If you have any questions about this Information or wish to exercise any of your rights, please contact us at e -mail: [email protected] or contact us by mail at the address indicated above.
IV. INSPECTOR OF PERSONAL DATA (IOD)
If applicable, you can also contact our Data Protection Officer. Data Protection Officer, who can be contacted by email or letter at the following addresses: [email protected]
V. PERSONAL DATA
1. Categories of persons to whom Personal Data relates:
– employees of Farmak international or other entities that cooperate with Farmak International
– employees of Farmak International
– principals and contractors of Farmak International
– Doctors
– Nurses
– Pharmacists
– other medical professionals
– other visitors to the website
2. “Personal data” is data that directly or indirectly identifies individuals.
3. Personal data that we collect or may collect include:
– name or names
– name or names
– name or names of family members
– name or names of family members
– gender
– address of residence
– residence, residence or mailing address with postal code
– date of birth
– PESEL or other identification number
– NIP
– identity card number or passport number
– number of other documents, including Doctor’s, Pharmacist’s license number and others
– citizenship
– circumstances related to employment (including period of employment, place of work, work experience)
– data on education, credentials, specializations, professional affiliations (e.g., membership in professional bodies), publications, competencies and other professional achievements)
– phone number, including cell phone number
– email address
– fax number
– information on current health status.
– preferred language.
– photo/image
– interests
– data on product use, interactions with Farmak International, preferred channels
– communications, including information on reporting adverse reactions
– financial and banking data, for payment of remuneration for services or reimbursement of expenses
– service, travel, accommodation and per diem expenses
– position, department of employment
– responsibilities
– data on absenteeism (vacation, sick leave, rehabilitation, training, other)
– information on penalties, rewards and others required under the Labor Code
6. HOW WE COLLECT PERSONAL INFORMATION
We collect Personal Data:
1. During face-to-face contacts, via electronic communications and:
– from signed contracts
– from telephone calls
– from signed statements and consents
– from other signed documents and surveys
– from participation in programs, activities, industry events, educational meetings, trade shows
– in connection with inquiries or messages addressed to Farmak International
– from companies providing IT services in the healthcare sector
– from publicly available sources
– from information within the scope of the profession
– from marketing partners
7. HOW WE PROCESS PERSONAL DATA
Operations or set of operations performed on Personal Data:
– collection
– fixing
– organizing
– organizing
– storage
– adapting or modifying
– downloading
– viewing
– use
– disclosure
– transmission
– matching or merging
– limiting
– removing or destroying
8.PURPOSE AND LEGAL BASIS FOR PROCESSING PERSONAL DATA
(1) Farmak International processes Personal Data only to the extent and for the purpose of:
(a) perform its duties as an Employer, in accordance with Article 6(1)(a), (b), (c), (f) of the RODO and Article 9(2)(b), (h) of the RODO
b) implementing legal obligations to monitor and report adverse reactions, receive reports on product quality or product safety, in accordance with Article 6(1)(c), (d), (e), (f) of the RODO and Article 9(2)(b), (c), (g), (i) of the RODO
(c) interaction and cooperation in the framework of contractual relations, or on the basis of consent, pursuant to Article 6(1)(b) of the RODO, or pursuant to consent Article 6(1)(a) of the RODO
(d) statistical or administrative, pursuant to Article 6(1)(f) of the RODO
(e) verification of professional credentials, in order to grant access to certain products, services and data, which may be shared only with persons authorized to practice health professions, pursuant to Article 6(1)(c), (f) of the RODO
(f) verification for anti-corruption and security assessment purposes of undertaking cooperation in accordance with Article 6(1)(f) of the RODO
g) conduct training and provide quality control including internal and external audits in accordance with Article 6(1)(b, f) of the RODO
h) identify, detect and prevent misconduct, including corruption in accordance with Article 6(1)(f) of the RODO
(i) to fulfill anti-corruption and transparency obligations in accordance with Article 6(1)(f) of the RODO
j) ensure the protection of the rights, privacy, security, and property of Farmak International in accordance with Article 6(1)(f) of the RODO
k) analyze and forecast preferences to identify aggregate trends for the purpose of developing, improving or changing Farmak International’s products, services and business operations in accordance with Article 6(1)(f) of the RODO
l) deliver marketing information and educational materials (by digital means or otherwise), which may be tailored to your area of professional specialization and interests, subject to your consent, in accordance with Article 6(1)(a) and (f) of the RODO
2. Interaction and cooperation with you includes:
(a) responding to your inquiries and requests
b) executing contracts concluded with you, e.g. sponsorship for scientific events or consulting meetings, etc. where applicable, paying you for the performance of certain services, reimbursing you for costs, expenses of attending meetings and others
c) sending you information related to the performance of contracts and documenting our interactions with you
(d) creating and maintaining a Farmak International database of health professionals working with Farmak International for the purpose of possibly contacting you (digitally or otherwise) as scientific experts or opinion leaders in health areas, and to record your previous interactions with Farmak International, for example:
– to invite you to participate in congresses/panels and other educational events
– to solicit your opinions and scientific information about our products through our representatives, as well as for surveys related to researching the quality of our services or products
3. Collaborating with a health professional includes:
(a) verifying whether you have the right to access certain products, services and data that may be provided only to certain authorized health professionals
(b) contacting you through digital means or otherwise engaging you in health professional programs/panels
c) engaging your expertise, such as in the context of surveys about the products or services of the Farmak International entity or its business partner.
d) interacting with you at medical events, publication meetings or consulting meetings.
(e) Gathering your opinions on products and services promoted by us, an affiliate or a business partner for the purpose of developing and improving those products and services
4. Conducting business with you, which includes:
– conducting data analysis and auditing
– analyzing the effectiveness of our communications
– detecting and preventing fraud and conducting investigations, including
– monitoring security (cyber security) and preventing breaches
– developing, improving, enhancing or modifying our products and services
– verifying your ability to access or use Farmak International products or services
– improving your understanding of how Farmak International’s products and services affect you
– responding to concerns, including exercising regulatory control and performing
– responsibility for reporting adverse events, product complaints and patient safety issues
– conducting and expanding the business activities of Farmak International
9. HOW WE DISCLOSE PERSONAL INFORMATION
1. We disclose Personal Data:
– to Farmak International’s external service providers so that they can provide data analysis services, provide information technology and related infrastructure, provide customer service, conduct audits and more.
– to companies that provide services in the field of creating and sharing databases in the health sector to check the validity of such data.
– to fulfill legal obligations, in connection with legal proceedings and inquiries from state authorities and institutions
10.RIGHTS OF INDIVIDUALS
1. You have the right:
(a) access to the content of your own Personal Data
b) their rectification or correction
c) their deletion or restriction of processing
(d) the right to data portability
e) to object, including objecting to automated processing of personal data
(f) to lodge a complaint with a regulatory authority
2. If you would like to review, correct, update, restrict processing, delete Personal Data that you have previously provided to us, or if you would like a copy of such Personal Data for transmission to another entity, you may contact us.
3. We will respond to your request in accordance with applicable laws and regulations.
4. Please be aware that we may retain certain Personal Data for record-keeping purposes or to carry out the services you have initiated prior to your request for amendment or deletion.
5. If your Personal Data has been provided with your consent, you have the right to withdraw your consent at any time, without affecting the compatibility of the processing carried out on the basis of your consent before its withdrawal.
11.DATA SECURITY
We use reasonable organizational, technical and administrative measures to protect your Personal Data. Your Personal Data is kept secure.
12.RETENTION PERIOD OF PERSONAL DATA
1. We will retain Personal Data for as long as necessary or permitted for the purposes for which it was obtained as described in this Notice. We consider the following criteria in determining the duration of the retention period:
– the duration of the relationship with you and providing you with access to the Site;
– the requirements of the laws that apply to us; or
– whether storing the information is advisable due to our legal interest (e.g., in connection with enforcement of the Site Rules, applicable statutes of limitations, litigation, or investigation activities of regulatory authorities).
13.TRANSFERRING DATA OVERSEAS
1. The data we collect through the Site may be stored and processed in any country where we have facilities or employ service providers, including the U.S., as well as where our affiliates or Farmak International companies operate in other countries.
2. Some of the countries outside the EEA are recognized by the European Commission as providing an adequate level of
3. Data protection in accordance with EEA standards3.
Regarding the transfer of information from EEA countries to countries not recognized by the European Commission as providing an adequate level of protection, we have put in place appropriate measures to protect your Personal Data, such as ensuring that the recipient of the information is bound by the EU Data Protection Standard Contractual Clauses. A copy of the documents setting out these safeguards can be obtained by contacting the Controller or the Data Protection Officer.
A copy of the documents specifying data transfer safeguards can be obtained at:
14.COOKIES
1. Cookies are a standard feature of websites. They allow us to store small amounts of data on your computer with information about your visit to our Site. Cookies help us learn which areas of the Site are useful and which areas need improvement.
2. Information about the cookies we use and your settings regarding cookies and similar technologies is available in the Cookie Consent Tool at the bottom right of the Website
3. You can refuse to accept or accept cookies from the Website at any time by toggling the appropriate settings in the browser you are using. Information on the procedure to be followed to enable or disable cookies can be found on the website of the browser manufacturer accessible through the help screen.
4. Please note that if cookies are disabled, your use of the Site may be limited and some features of the Site may begin to malfunction. We may also use technologies similar to cookies, such as:
– Pixel tags. Pixel tags (also known as beacons and clear GIFs) are used, among other things, to track the actions of Site users, measure the effectiveness of our marketing campaigns, and produce statistics on Site usage and response rates.
– Adobe Flash. Locally Shared Flash Objects (also known as Flash cookies lkub “Flash LSOs”) and other technologies are used to, among other things, collect and store information about how you use the Site. For options regarding Flash LSOs, please visit this page. Please note that setting the Flash player to restrict the reception of Flash LSO elements may reduce or hinder the functionality of some Flash applications.
– Google Analytics. Google Analytics is a service provided by Google, Inc. (“Google”). Google Analytics service to collect anonymous statistics to improve our Site. Learn more about Google Analytics and its privacy policy. You can selectively disable Google Analytics by installing an opt-out component offered by Google in your browser.
5. Some information is collected by most browsers or automatically through your device. This includes your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, browser type and version, and the name and version of the Site you are using. We use this information to ensure the proper operation of the Site. Other sections of this Privacy Notice apply to the collection of personal information through cookies or similar technologies.
15. MINORS
If the child is under 16 years of age, such processing of Personal Data shall be lawful only in cases where consent has been given or approved by the person with parental authority or custody of the child, and only to the extent of the consent given. The Personal Data Controller, taking into account the available technology, shall make reasonable efforts to verify whether the person with parental authority or custody of the child has given or approved the consent.
16.FILING A COMPLAINT WITH A REGULATORY AUTHORITY
1. You may file a complaint with the competent data protection authority in your country or the place where your rights have been violated.
2. To obtain contact information for data protection authorities. In the case of Poland, the competent authority is the President of the Office of Personal Data Protection.
3. Inspector of Data Protection: