This Privacy Notice was last updated on December 27, 2022.
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
The data controller is Pharmacosmos A/S, Roervangsvej 30, DK-4300 Holbaek, Denmark.
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:
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:
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:
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 1 year after the event with the exception of photos which will be stored for up to 5-7 years.
Recordings:
When you give a lecture or other scientific presentation, we may take photos of and record (audio and/or video) you during such presentation for the purpose of publishing, distributing and using the photos and recordings to promote and inform about healthcare subjects, our products and our business. Publication of the recordings may take place in any form and through any medium. When publishing the photos and recordings, we may also publish your name, job title and place of work. Our legal basis for such processing of your Personal Data is the GDPR article 6(1)(a) – your consent, or the GDPR article 6(1)(b) – our performance of a contract with you.
The recordings will be stored until the scientific presentation becomes outdated.
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:
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, may happen on an ad hoc basis in accordance with GDPR Article 49 (1), (b) to (e), and will otherwise be safeguarded by ensuring that the third party enters into the EU Commission’s Standard Contractual Clauses.
You may request a copy of the relevant Standard Contractual Clauses by contacting Pharmacosmos A/S on: dataprotection@pharmacosmos.com
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.
You have the following rights in relation to your Personal Data:
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
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)
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 30, DK-4300 Holbaek, Denmark or by email to: dataprotection@pharmacosmos.com
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 4: 2022-12-27
