Introduction
The Company A. Menarini Portugal – Farmacêutica, S.A. (“Company”, or “we”) takes its users’ privacy very seriously and undertakes to comply in full with the applicable law (Regulation (EU) 2016/679 – hereinafter defined as the “GDPR”).
This document (“Privacy Policy”) provides information on how the personal data collected by the Company through this website (“Website”) are processed, and constitutes “an information notice to the data subjects” under the terms of art. 13 of the GDPR. Specific privacy information notices are normally published in the Website sections in which users’ personal data are collected; in any event these are supplemented by this Privacy Policy.
1. Data Controller and DPO
The Data Controller is A. Menarini Portugal – Farmacêutica, S.A., with registered offices in Quinta da Fonte, Edifício D. Manuel I, Piso 2-A, Rua dos Malhões, nº 1 2770-071 Paço de Arcos (“Controller”).
The Data Protection Officer (“DPO”) can be contacted at the following address: dpo@menarini.com
2. The Data we process
With your consent, we process the following personal data that you provide to us when you interact with the Website and use the related services and functions. These data include, in particular, name and surname, contact details (email and telephone number), interests and additional data that the Controller may acquire, also from third parties, in the course of business (“Data”).
If you consent (optional) for profiling purposes, the following data will also be processed: user, session, date and time, page visited, time spent on the page, video playback, articles downloaded or viewed, etc.
In order to allow us to manage your registration in the restricted access area, you must consent to the processing of data marked with an asterisk (*). Without this mandatory data or your consent, we will not be able to proceed. On the other hand, the information requested in the fields not marked with an asterisk is optional: failure to provide them will not have any consequences.
Consent for profiling is also optional: if you do not provide it, or if you revoke it, only anonymous information about your browsing activities in the restricted access area will be collected.
In any case, even without your prior consent, the Controller may process your data to comply with legal obligations arising from EU laws, regulations and legislation, to exercise rights in legal proceedings, to pursue its own legitimate interests and in all cases provided for in articles 6 and 9 of the GDPR, when applicable.
The processing is carried out both by computer and paper means, and will always imply the implementation of the security measures provided for by the law in force.
3. Why and how we process your personal data
The Data is processed to manage your requests for information/registration in areas of restricted access submitted through the Website and the form; the legal basis for processing personal data for this purpose is your consent (art. 6.1. (a) and 9.2.(a) of the Regulation).
In addition, but only with your optional consent, which forms the legal basis for processing pursuant to Article 6.1 (a) GDPR, the data is processed:
i. to receive Controller Newsletters. Please be informed that our Newsletters may contain a “Pixel Tag”, through which the Controller detects certain information, such as if and when you opened and/or deleted the email, which links were contained in the newsletter you clicked on, whether the email was opened by more than one IP address, as well as aggregated and anonymous information about its approximate location, etc. The Controller processes this information to verify the effectiveness of its information campaigns, based on art. 6.1. (f) of the Regulation. Many email service providers and customers have a specific setting through which you can disable this detection – check the specific settings if you do not want the Controller to detect the mentioned information;
ii. to create profiles based on your needs, interests and preferences, in order to improve the service and offer personalized content (“profiling”).
By selecting the relevant options and ticking the consent box, you agree to the processing of your personal data for the purposes described above, as described in this information note.
You may, at any time, revoke the consent(s) you have given for the aforementioned purposes - to do so, you must proceed as follows:
– close your account in the restricted access area: log in and click on the “Delete account” button;
– newsletter subscription: use the unsubscribe link displayed in each newsletter you receive from us;
– profiling: uncheck the box included in the restricted access area.
Your data may, in any case, be processed, even without your consent, for the purposes of complying with laws, regulations, EU legislation (art. 6.1. (c) of the GDPR, to carry out statistics on the use of the Website and ensure its correct functioning (art. 6.1. (f) of the GDPR), to enforce the Menarini Group Code of Conduct and to establish or defend legal rights in the interests of the Company (art. 6.1. (f) and art. 9.2. (f) of the GDPR).
Personal data are entered into the Company's computer system in full compliance with the data protection law, including security and confidentiality profiles and based on principles of good faith, legality and transparency in processing.
The Data are kept for the time strictly necessary to obtain the purposes for which they were collected (for example, until you cancel your subscription to the newsletter or the reserved area) and in accordance with the deadlines established by law and the principles of minimization. of data, limitation of storage and rational management of files.
All your Data will be processed on paper or through automated instruments, which in any case guarantee an adequate level of security and confidentiality. With reference to profiling, we inform you that browsing data will be deleted after 12 months of collection.
4. Necessary processing and optional processing
The forms to be completed on this website require you to confer personal data which are strictly necessary to handle your communications and requests. Such Data are marked with an asterisk [*]. If you do not wish to confer them, we will not be able to handle your communication/request. Conversely, forms may also provide the possibility to confer personal data which are not strictly necessary to handle your requests: providing such data is optional - failure to do so has no consequence.
5. Browsing data
If you only visit the Website (i.e., without sending communications or using any of the available services/functions), the processing of your data is limited to browsing data i.e., data whose transmission to the Website is necessary for the functioning of the computers which operate the Website and of the Internet communication protocols. This category includes, for example, IP addresses or computer domain used to visit the Website and other parameters pertaining to the operating system used to connect to the Website. The Company collects these and other data (such as, for example, number of visits and time spent on the Website) merely for statistical purposes and in anonymous form in order to monitor the functioning of the Website and improve its performance. Such data is not collected to be associated with other information regarding, or for the identification of, users; however, such information, by its very nature, may enable the Company to identify users through processing and association with data held by third parties. Browsing data are normally deleted following processing in anonymous form but can be stored and used by the Company to detect and identify perpetrators of any computer offences committed to the detriment of the Website or using the Website. Without prejudice to this possibility and to the provisions of the Cookie Policy, the browsing data described above are stored only temporarily, in compliance with law.
6. Links to other websites
This Privacy Policy applies only to the Website as defined above. Even though the Website may contain links to other websites (known as third party websites), please be informed that the Company does not perform any access or control over cookies, web beacons or other user-tracking technologies that may be active on such third party websites, on the contents and materials published thereon, or on their methods of processing of your personal data; for this reason, the Company expressly declines any liability for such matters. You should therefore verify the privacy policies of such third party websites and collect information about their terms and conditions and about how they process your personal data.
7. How we store data and for how long
In compliance with Article 5.1.(c) of the GDPR, the computers and programmes used by the Company are set up in such a way to reduce the use of personal and identifying data to a minimum. Such data are processed only to the extent required to achieve the purposes indicated in this Policy, and will be stored for as long as strictly necessary for achievement of the specific purposes pursued - in any event, the criterion used to determine the storage period is based on compliance with time limits permitted by law and the principles of data minimisation, storage limitation or rational management of our records.
8. How we ensure your personal data’s security and quality
The Company undertakes to ensure security of the user’s personal data and comply with provisions on security provided by law to avoid data loss, illegitimate or unlawful uses of data or unauthorised access to data, with particular but not exclusive reference to Articles 25-32 of the GDPR. The Company uses many types of advanced security technologies and procedures intended to aid protection of the user’s personal data; for example, personal data are stored on secure servers situated on premises with protected and controlled access. The user can assist the Company to update and correct their personal data by communicating any change of address, qualifications, contact information, etc.
9. Persons who have access to the data
Persons belonging to the following categories are authorised to process the user’s data: technical and administrative staff, IT staff, product managers, etc., as well as other staff members who require processing the data for performance of their job duties.
The Data can be communicated also in countries outside the EU (“Third Countries”) to other companies of the Menarini Group for the same purposes and/or for administrative and accounting purposes pursuant to Article 6.1.(f) and Recital 48 of the GDPR.
Additionally, the Data can be communicated, also in Third Countries, to: (i) institutions, authorities, public bodies for their institutional purposes; (ii) professionals, independent consultants –working individually or in partnerships- and other third parties and providers which supply to the Company commercial, professional or technical services required to operate the Website (e.g., provision of IT and Cloud Computing services) for the purposes specified above and to support the Company with the provision of the services you requested ; (iii) third parties in the event of mergers, acquisitions, transfers of business -or branches thereof-, audits or other extraordinary operations; (iv) the Supervisory Board, based at the Controller’s address, in the pursuit of its supervisory activities and for the enforcement of the Menarini Group Code of Conduct. The mentioned recipients shall only receive the Data necessary for their respective functions and shall duly undertake to process them only for the purposes indicated above and in compliance with data protection laws. The Data can furthermore be communicated to the other legitimate recipients identified from time to time by the applicable laws. With the exception of the foregoing, the Data shall not be shared with third parties, whether legal or natural persons, who do not perform any function of a commercial, professional or technical nature for the Controller and shall not be disseminated. The parties who receive the Data shall perform processing as Data Controller, Processor or persons authorised to process personal data, as the case may be, for the purposes indicated above and in compliance with the applicable data protection law.
Regarding any transfer of Data outside the EU, including in countries whose laws do not guarantee the same level of protection to personal data privacy as that afforded by EU Law, the Controller informs that the transfer shall in any event take place in accordance with the methods permitted by the GDPR, such as, for example, on the basis of the user’s consent, on the basis of the Standard Contractual Clauses approved by the European Commission, by selecting parties enrolled in international programmes for free movement of data or operating in countries considered safe by the European Commission.
10. Your Rights
You may at any time exercise the rights afforded by Articles 15-22 of the GDPR, including the right to obtain confirmation of the existence of personal data which relate to you, check its content, origin, correctness, location (also with reference to any Third Countries), request a copy, request correction and in cases provided by law, restriction of processing, deletion, oppose to direct contact activities (also limited to particular means of communication). Likewise, you may always withdraw consent and/or make observations on specific issues regarding processing operations of your personal data which you regard as incorrect or unjustified by your relationship with the Company, or lodge a complaint with the Data Protection Authority.
You may contact the Controller and/or DPO at the addresses displayed above to make any requests regarding personal data processing by the Company, to exercise your legal rights and to obtain an updated list of the parties who have access to your data.