PRIVACY NOTICE


HEALTH CARE PROFESSIONAL


PRIVACY NOTICE OF PERSONAL DATA PROCESSING RELATED TO HEALTH CARE PROFFESIONALS REGARDING PROFESSIONAL COLLABORATION ON IRON DEFICIENCY


This Privacy Notice was last updated on April 12, 2021.

If you contact us to report a complaint or safety information, such as adverse effects, concerning our products, we are under specific legal obligations. Therefore, your Personal Data will be processed as described here: https://www.pharmacosmos.com/contact-us/privacy-notice-safety-information

IDENTITY OF THE DATA CONTROLLER


The data controller is Pharmacosmos A/S, Roervangsvej 43, DK-4300 Holbaek, Denmark.

Purpose of processing your personal data


Pharmacosmos A/S will collect and process your Personal Data for the purposes described below. 

To carry out our professional collaboration with you:

To carry out and continuously improve our professional collaboration regarding iron deficiency, your professional contact information such as your name, email, phone number, job title, specialisation, place of work, qualifications, address, and educational background, photo and CV may be stored in our databases.

We will process such Personal Data in relation to booking of meetings, publications, training, invitations and other collaborative work.

Our legal basis for such processing of data is the General Data Protection Regulation (“GDPR”), article 6(1)(f) - our legitimate interest in maintaining and continuously updating a CRM database containing contact information of relevant HCPs.

The Personal Data will be stored for the duration of our current or potential professional collaboration.

Contractual relations:

If we enter into an agreement with you for your provision of services or otherwise to Pharmacosmos A/S, we may, in addition to the information above, collect:

  • your bank account information
  • your personal identification number or authorization ID (where required)
  • images, voice and video recordings
  • details on services provided by you as well as any remuneration for such services,

and process the data for the purpose of accomplishing the purpose of the agreement and performance of our contractual obligations.

Our legal basis for such processing of your Personal Data is:

  • GDPR article 6(1)(b): Performance of contract,
  • GDPR article 6(1)(c): Complying with legal obligations on disclosure of transfer of value, and
  • GDPR article 6(1)(f): Legitimate interest in assessing adherence to local law and industry standards and assessing fair market value.

The Personal Data processed to comply with the requirements of the Danish Medicines Agency to report annually regarding transfers of value, will be stored for 13 months.

Agreements will be stored for 10 years after the end of the collaboration to ensure legal and regulatory compliance and to ensure adequate documentation and protection in relation to, amongst others, future legal disputes.

Medical Information Management System:

When entering medical queries, adverse events, and product quality complaints received from you in our Medical Information Management System, we will also record your Personal Data such as name, address, email, fax and phone number.

The Personal Data will be stored for 10 years after entering of data. Personal Data collected in connection to an ADR will be kept for the following period of time:

  • 12 years for data relating to technical complaints
  • Permanently for data relating to adverse events and other experiences
  • Up to 5 years for all other enquiries

Events:

In connection with attending our events, we might collect Personal Data such as your name, email, specialization, job title, dietary requirements, address, educational background, photo, phone no., place of work and travel data.

Our legal basis for such processing of your Personal Data is the GDPR article 6(1)(a) - your consent.

The Personal Data will be stored up to 3 years after the event.

Confidentiality and processing of your personal data


Your Personal Data will be treated as confidential information by those who are allowed to process your Personal Data and will only be used for the purposes described in this privacy notice.

It will be stored by Pharmacosmos A/S or a third-party hosting provider.

When needed, Pharmacosmos A/S may transfer your Personal Data to our affiliated companies and other third parties:

  • Service providers assisting Pharmacosmos in relation to meetings, events (on-site and virtual) or other arrangements with your participation
  • Other suppliers and vendors that we work with to assist our company, including technical support, supply services and financial institutions
  • Pharmacosmos A/S’ group entities
  • Public authorities
  • Local industry associations.
  • Journals
  • Other HCPs

TRANSFER OF YOUR PERSONAL DATA OUTSIDE THE EU/EEA


If your Personal Data is transferred to one of our affiliated companies or a third party located in a country outside the EU/EEA, Pharmacosmos A/S will ensure that such transfer(s) will be carried out in accordance with the applicable data protection legislation, including the GDPR.

If your Personal Data is transferred to our affiliated companies outside the EU/EEA, not ensuring an adequate level of data protection, the transfer will be based on Intra-Group Agreements including the EU Commission’s Standard Contractual Clauses.

Transfers to third parties outside the EU/EEA, not ensuring an adequate level of data protection, will be safeguarded by ensuring that the third party enters into the EU Commission’s Standard Contractual Clauses.

More information can be obtained by contacting Pharmacosmos A/S on  dataprotection@pharmacosmos.com 

RETENTION/STORAGE PERIOD OF YOUR PERSONAL DATA


Your Personal Data will be retained for as long as it is relevant to fulfill the purpose for which it has been registered and in accordance with any specific retention periods required by law.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA


You have the following rights in relation to your Personal Data:

  • To access your Personal Data held by Pharmacosmos A/S
  • To have your Personal Data corrected, for example, if it is incomplete or incorrect
  • To opt out of receiving marketing communications at any time
  • To restrict or object to the processing of your Personal Data or request erasing of your Personal Data (in certain circumstances and subject to applicable law)
  • To receive a copy of your Personal Data, in a structured, commonly used and machine-readable format (known as “data portability”) (in certain circumstances and subject to applicable law)
  • Where you have provided personal data voluntarily, or otherwise consented to its use, the right to withdraw your consent
  • The right to complain to a data protection authority (see section “Complaints”)

In the event of an erasure request, we may retain a copy of your Personal Data for record-keeping purposes and to avoid entering your Personal Data in our systems after your request.

To exercise any of these rights, please contact our Data Protection Officer at dataprotection@pharmacosmos.com

COMPLAINTS


If you are concerned about an alleged breach of privacy law or any other regulation by Pharmacosmos A/S, you can contact us (see contact details below). The complaint will be handled in accordance with applicable law. 

If you are not satisfied with the way in which Pharmacosmos A/S has resolved your complaint, you have the right to complain to the data protection authority in your country (for Denmark: the Danish Data Protection Agency at: dt@datatilsynet.dk)

CONTACT INFORMATION


If you have questions or you do not feel that your concerns have been addressed in this Privacy Notice, please contact us either by mail, Attention: “Data Protection Officer” to the address: Pharmacosmos A/S, Roervangsvej 43, DK-4300 Holbaek, Denmark or by email to: dataprotection@pharmacosmos.com 

UPDATES TO THIS PRIVACY NOTICES


From time to time, we may revise this Privacy Notice. Any such changes to this Privacy Notice will be reflected on this page. Pharmacosmos A/S recommends that you review this Privacy Notice regularly for any updates. The date on which this notice was last revised is located at the top of this Privacy Notice.

Privacy notice of personal data processing related to health care professionals version 2: 2021-04-12

Pharmacosmos