Privacy Policy for HCP

Privacy Policy for HCP

Dear Doctor / Health Care Professional

We take the privacy of your data very seriously and we are committed to complying with the highest standards in this field. For this reason, we intend to provide you with up-to-date information on how A. MENARINI PORTUGAL - FARMACÊUTICA, S.A., based at Quinta da Fonte, Edifício D. Manuel I, Piso 2 A, Rua dos Malhões, nº 1, 2770- 071 Paço de Arcos (hereinafter the "Company" or "we") processes your personal data and ensures compliance with applicable legislation, including the Regulation 2016/679/EU (the "Regulation").

1.      What we can do with your Data

The personal data you are transmitting to us, or that you have transmitted on the occasion of previous contacts, may be processed by A. MENARINI PORTUGAL - FARMACÊUTICA, S.A., as Responsible for Treatment, for the following purposes:

(A) "Scientific Information Activities", which also include contacts for scheduling and carrying out medical information visits, for which purpose any of the contacts you have provided us with may be used, as well as digital means of communication, such as emails

(B) "Institutional Communication Activities", also carried out through digital communication media, such as emails, related to the Company or its initiatives and products.

(C) Customisation of the activities/services relating to our Scientific Information, through the determination of your needs, preferences and professional interests, in this context you may receive invitations to attend or to be offered professional collaboration for congresses, training sessions, clinical sessions, workshops and other scientific events that A. Menarini Portugal - Farmacêutica, S.A. organises or in which it participates.

2.      What Data we collect

The personal data we collect ("Data") is as follows:

(1)   Professional/Academic title; (2) First name; (3) Surname; (4) Date of birth; (5) Date of graduation; (6) Sex; (7) Clinical name; (8) Addresses for correspondence and visits (street, number, city, postal code, as well as email address); (9) professional telephone number; (10) professional mobile phone number; (11) Additional professional and academic qualifications/specializations; (12) professional position; (13) agreements with the National Health Service; (14) details of scientific or any other event attended by the healthcare professional and supported by the Company; (15) details of samples provided; (16) details of the use/viewing by you of our information materials made available electronically/digitally; (17) Medical practitioner number.

Consent to the processing of data is essential for the development of our scientific information activities. For this reason, we ask you to provide us with the above data: if you do not provide them we will be unable to send you Scientific Information or communication on related activities. Your consent to collect all other data listed above, and to process them for the additional purposes indicated above (i.e. for non-Scientific Information purposes), is optional - your refusal will not prevent us from sending you communication about Scientific Information activities although we may not be able to tailor our services to your needs and/or update you on Company or Group news.

We inform you that your consent constitutes the legal basis for the data processing operations described above, in accordance with art. 6.1.a of the "Regulation". In addition, your data may also be processed without your consent, for compliance with obligations arising from national and European Union laws and regulations, to enforce or judicially defend a right, for the pursuit of legitimate interests (e.g.: the sharing of data between Companies of the Menarini Group) and in the other cases provided for in Art. 6 and 9 of the "Regulation", where applicable.

3.      How we treat your Data

Data is processed on paper and electronically, and entered into the systems of the "Company" in accordance with applicable legislation - including with regard to data security and confidentiality - and in accordance with the principles of proper and legitimate treatment. Your Data will be kept for the period of time strictly necessary to fulfil the purposes for which they are collected; in any case, the criterion used to determine the length of time for which they will be kept takes due account of the need to comply with legal obligations, the principle of data minimisation and the need for rational management of the "Company's" records. We may keep your data even after the end of the activities that we maintain with you, but only for the period of time necessary for the fulfilment of legal and contractual obligations, as well as for the fulfilment of the purposes previously mentioned. A. MENARINI PORTUGAL - FARMACÊUTICA, S.A. may interconnect personal data by relating the data in one file with the data in another file or files held by us or third parties. We update and maintain our databases in order to ensure that your data is always correct and accurate.

4.      Who can access your data

Data may be processed by employees belonging to the following categories: administrative staff, sales staff and product managers. The data may also be processed by any other employee who needs to do so as a result of the duties assigned to him/her. Additionally, in accordance with articles 6 and 9, and recitals 48 and 52, of the "Regulation", the Data may be transmitted to the Parent Company, A. Menarini IFR Srl, with registered office in Florence (Italy), as well as to other companies of the Menarini Group (even those not based within the EU - "Third Countries") for organisational, administrative, financial and accounting needs. In accordance with the legal and regulatory obligations to which we are bound, we may communicate your Data to INFARMED, APIFARMA, the national and local Health Authorities, other health centres and universities, other public authorities, associative entities, as well as other recipients to whom your Data should be communicated to comply with legal or regulatory obligations. Additionally, and in accordance with the obligations and purposes stated above, the data may be communicated to other companies, such as suppliers, sub-suppliers, cloud computing and IT service providers, agencies and event organizers, professional service providers and companies that perform administrative/taxation tasks on our behalf, even if in Third Countries. These entities/individuals will act, depending on the circumstances, either as a controller or as a processor, for the same purposes as indicated above and in accordance with applicable law. With regard to the transfer of Data to Third Countries - including to countries that do not ensure the same standards of protection under applicable privacy laws, we inform you that the processing of Data will only take place in accordance with the provisions of applicable law, such as, for example, your consent, the adoption of the Model Contractual Clauses approved by the European Commission, the selection of business partners enrolled in international free data transfer programs (e.g. the EU-USA Privacy Shield) or operating in Countries considered safe by the European Commission.

5.      Your Rights of Access and Control

You may contact us at any time at, as well as our postal address, to exercise your rights under articles 15-22 of the Regulation, including: know whether we are processing any Data concerning you; access your Data; check the content, origin, accuracy, location (including, where applicable, the Third Countries where the Data may be); obtain a copy of the Data; request that the Data be completed, updated, corrected; in the cases provided by law, request that Data processing be restricted, that Data be erased, anonymised, frozen; exercise the right to object to profiling operations and direct contact activities (including limiting the method of contact to specific means of communication), object to Data processing on legitimate grounds. Similarly, you may withdraw consent at any time (although withdrawing consent does not affect the legitimacy of the processing operations carried out before its withdrawal) and / or notify the Data Protection Officer of the Menarini Group ( of any fact related to the processing of your Data that you consider inappropriate and / or lodge a complaint with the National Data Protection Commission, with the following addresses: Rua de São Bento n.º 148-3º 1200-821 Lisbon and

Having read the above information, I hereby consent to the processing of my Data for the following purposes, as documented by the Commercial:

A)     "Scientific Information Activities", in which the contacts for scheduling and carrying out medical information visits are also included, and for this purpose any of the contacts that you have made available to us may be used, as well as being carried out by digital means of communication (such as emails).


I agree_____ (necessary)                                                     I do not agree_____    


B)       Receive institutional communications or communications about initiatives and products of the Company, also by digital communication means (such as emails).


I agree_____ (Optional)                                                      I do not agree_____    


C)       To receive customised scientific information, activities / services from the company based on my needs, preferences and professional interests and within this scope I may receive invitations to attend or to be offered professional collaboration for congresses, training sessions, clinical sessions, workshops and other scientific events organised by A. Menarini Portugal - Farmacêutica, S.A. or in which I participate.


I agree_____ (Optional)                                                          I do not agree_____