When registering or navigating through the website http://www.insudpharma.com(the “Website”) you accept this Privacy Policy. INSUD PHARMA, S.L.U. (“INSUD PHARMA”), and all the subsidiaries located in Spain, EU or third countries and dedicated to pharma sector are globally known as Insud Pharma (hereinafter, “Insud Pharma Group”).
Who is the Controller of your data?
The identification of the data controller in charge of processing your data and the data protection officer are the following:
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Corporate name |
INSUD PHARMA, S.L.U. |
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Registered office |
Calle Manuel Pombo Angulo, 28 3ª planta 28050 Madrid, Spain. |
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Tax Identification Number |
B-85212165 |
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Telephone |
+34 917711500 |
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dataprotection@insudpharma.com |
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Companies House Information |
Commercial Registry of Madrid, Page M-326179, Volume 34641, Sheet 10 |
To contact the Data Protection Officer, you may send an email to the following addressDPO@insudpharma.com.
Which kind of data is collected by INSUD PHARMA and what is the purpose for the processing of your personal data?
Personal data collected through the Website will be duly incorporated in the data file “COMMUNICATIONS” under the responsibility of INSUD PHARMA which will be registered in INSUD PHARMA´s record of processing activities.
Personal data consists of information that allows identifying individual individuals, such as name, postal address, email or telephone number. We only collect personal data provided by the User through our Website.
In particular, INSUD PHARMA collects the following personal data provided by the User:
User communications: it includes any personal data provided by the User in the course of the communications with INSUD PHARMA related to incidents, complaints or any other.
When completing the Website registry process through the section “Join our team”, the User will provide the CV, personal data and professional information in order to take part in the recruitment procedure. Therefore, the candidate could send the CV as spontaneous application.
When a candidate provides his/her CV and personal data in a recruitment procedure, INSUD PHARMA must collect his/her express consent for sending commercial communications and in order to maintain the CV for future recruitment procedures.
When reporting an adverse drug reaction through the section “Pharmacovigilance”
In addition to personal data referred to in the previous section, INSUD PHARMA collects information automatically obtained by the Website which is related to the identification of the User’s computer equipment, the Website use and navigation habits. The said information includes data regarding language, pages or sections of the Website, keywords, date, time, amount of time the User expends in certain types of webpages, which section of the page he has visited and similar information related to the use of the Website. INSUD PHARMA may collect this information thanks to the use of cookies. For additional information check our Cookies Policy.
INSUD PHARMA may combine your personal data with other information provided by the User or collected from the Website as above mentioned. In those cases, all combined information will be processed as personal data during the period the information remains combined.
Any personal data collected by INSUD PHARMA may be used for any of the following purposes:
To manage the adequate functioning of the Website and to provide the User with appropriate means for its use.
To analyse and to improve the use of the Website.
To provide the User with information related to the activities performed by INSUD PHARMA or any other company part of Insud Pharma Group.
To solve any requests or complaints through the available channels: email and telephone service.
To contact the User in order to conduct a job interview.
To contact the User in case of conducting an adverse drug reaction
To send commercial communications, newsletters, and emails related to INSUD PHARMA and any other company part of Insud Pharma Group, by any means, including electronic means.
To create profiles with the collected information.
In the event INSUD PHARMA collects your personal data for purposes other than those abovementioned the User will be previously informed, and such communication will include the relevant information and the consequences of the processing of the personal data.
As User, at any time you have the possibility to exercise your right to object to the processing of your personal data by sending an email to dataprotection@insudpharma.comwith the subject “DATA ERASURE”.
INSUD PHARMA will store and process your personal data for the above mentioned purposes for an indefinite period and without determining a maximum conservation period. However, the User is entitled to revoke his consent at any time, and to ask INSUD PHARMA to delete his/her personal data from the database. If requested, INSUD PHARMA will keep the remaining information blocked and will apply the security measures established by law for the statutory limit period foreseen at the applicable legislation in connection to those proceedings that may be initiated against INSUD PHARMA.
What is the legitimacy for the processing of your data?
The legal basis for data processing is legitimate interest in order to allow the proper functioning of the Website and to provide information related to INSUD PHARMA with the purpose of attending Users requests.
The legal basis for the data processing will be User’s consent in the following events:
When the User provides us with their CV and personal data in order to participate in a recruitment procedure, the legal basis for the data processing will be User’s consent.
When the User contacts with INSUD PHARMA through the contact forms included in the section “Shall we talk?”
When the User contacts with INSUD PHARMA through the contact forms included in the section “Pharmacovigilance”
To which addressees will your data be transferred?
For internal purposes the personal data collected by INSUD PHARMA through the Website may be transferred to other companies’ part of Insud Pharma Group which are located within the European Economic Area (EEA) or in third countries.
The User expressly accepts any personal data may be subject to international transfers to other subsidiaries of Insud Pharma Group located outside the EEA or not considered as safe harbour may take place.
INSUD PHARMA virtual infrastructure is contracted following a cloud-based model through an operator located within the European Economic Area (EEA).
All data communications will be made in compliance with current personal data legislation and in particular with those introduced by Regulation (EU) 2016/679 of the Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”).
INSUD PHARMA may disclose User’s personal data to any public administration, when required by law and compelled to do so by such authorities.
What are your rights when you provide us with your data?
At any time you may exercise before INSUD PHARMA your rights to access, rectify, erase and oppose (ARSO), pursuant to the applicable legislation. This means you can ask what personal data we have about you, update, or you can request that INSUD PHARMA stops using data for a specific purpose, or simply require INSUD PHARMA to delete all personal data from our files and databases.
In the event the User decides to oppose to the processing of the personal data, INSUD PHARMA will no longer process personal data in connection to such User. Personal data may still be processed for the purposes established in data protection legislation or bring defence against legal claims.
Moreover, the User may be able to exercise the following rights before INSUD PHARMA:
Right to erasure, allowing the User to obtain the erasure of his personal data when the personal data held by INSUD PHARMA is excessive, obsolete or not accurate.
Right to data portability, allowing the User to receive all personal data provided to INSUD PHARMA, in a structured, commonly used format as well as the right to transfer those data to another platform.
Right to restrict data processing, in the following cases: (i) when the accuracy of the personal data is contested by the User, for a period enabling INSUD PHARMA to verify the accuracy of the personal data; (ii) the data processing is unlawful, and the User opposes the erasure of the personal data and requests the restriction of their use instead and (iii) INSUD PHARMA no longer needs the personal data for the purposes of the processing , but they are required by the User for the exercise or defence or legal claims.
After the User exercises any of the abovementioned rights, and during INSUD PHARMA´s verification period, all personal data will be kept blocked. The blocking procedure will prevent INSUD PHARMA from processing or erasing such personal data.
For the exercise of any of the abovementioned rights, the User shall contact INSUD PHARMA by email, addressing the request to dataprotection@insudpharma.com, indicating as reference: “EXERCISE OF RIGHTS” and identifying at the right to be exercised.
Additional information:
What is Data Quality?
The User warrants and represents before INSUD PHARMA as well as any other third party, the quality of the information provided, that is, that the data and information provided is true, accurate, updated and it belongs to the User and not to third parties. Therefore, by providing to INSUD PHARMA the personal data and the information the User decides to submit to the account, the User represent and warrant to INSUD PHARMA and to any other third party that provided personal data is accurate and complies with the principle of quality.
In any case, the delivery of false or outdated data is forbidden. The User shall identify himself with its real name and with accurate and current data. Through the Website INSUD PHARMA reserves the right to verify this information at any time by means of requiring the User to provide any official documentation that may serve as personal identification.
The User shall immediately communicate to INSUD PHARMA any change in connection to its personal data so that the information contained in the data files is updated and presents no errors.
What happens with the links from third parties?
This Privacy Policy exclusively refers to the Website and does not apply to third parties links or websites accessible through the Website.
The destinations of these links are not under control of INSUD PHARMA and it will not be responsible for the content of any of the destination websites of a link, or any link included in a website that is reached from the Website, or any change or update of these pages. These links are provided only to inform the User about the existence of other sources of information on a specific topic, and the inclusion of a link does not imply the approval of the linked website by INSUD PHARMA. Therefore, we recommend that you read and carefully the privacy policy of each website you visit.
What are Cookies and what are they used for?
To obtain additional information on how cookies are used in the Website and its deactivation please visit the Cookies Policy[M1] .
What security measures have INSUD PHARMA and the companies of Insud Pharma group adopted to guarantee the integrity of your data?
INSUD PHARMA cares to ensure the security and confidentiality of the Users personal data. Therefore, we have taken several security measures and technical means to prevent the loss, misuse or access to the personal data without the User permission.
Nevertheless, it is also the User responsibility to control the personal information and therefore INSUD PHARMA asks and encourages all Users to be careful with the shared information and content. INSUD PHARMA shall not control the content and information the User chooses to share with other Users and, therefore, INSUD PHARMA is not responsible for the consequences of the Users own actions.
INSUD PHARMA pledges (i) to act rapidly and in a responsible manner in the event the Users personal data security is deemed at risk, and (ii) to report it if relevant with the greatest diligence.
In case of a personal data breach, INSUD PHARMA undertakes to notify the Spanish Data Protection Authority (SDPA) with undue delay and not later than seventy-two (72) hours after becoming aware of such breach. Likewise, when the personal data breach is likely to result in a high risk to the rights and freedoms of Users, INSUD PHARMA will communicate the personal data breach and the measures taken to mitigate the risks and adverse effects to Users.
The Privacy Policy could be modified?
Yes. INSUD PHARMA reserves the right, at our sole discretion, to modify or replace this Privacy Policy. Your continued use of the Website after any such changes constitutes your acceptance of the new Privacy Policy.
Please review this agreement every so often in order to acknowledge any possible modifications. If you do not accept this document, partially or as a whole, or any subsequent modification, please refrain from the use, access or continue to access the Website or discontinue any use of the Website immediately.
We inform you that INSUD PHARMA uses a technology called “Cookies” with the purpose of facilitating User’s navigation and providing him information during their use of our Website.
In INSUD PHARMA we fulfil with the provisions of Cookies regulations, in particular Law 34/2002 on Services of the Information Society and Electronic Commerce of 11 July, related to the Directive 2006/136/CE. The User will be able to find in this Cookies Policy information related to the types of Cookies that we use, the purpose for their use and the different options for managing or deleting them. If you require additional information on Cookies that are used in the Website, please contact by email dataprotection@insudpharma.com.
What are cookies?
A Cookie is a file that may be stored on your computer or mobile device with the purpose of storing data that may be updated and recovered by the company responsible for its installation, this is INSUD PHARMA. This may include which pages you have visited, choices you have made from menus, any specific information you have entered into forms and the time and date of your visit.
What types of cookies do we use and for what purpose?
Cookies in our Website are only related to an anonymous user and his computer equipment. These Cookies will never collect user’s personal data or information to obtain user’s personal data indirectly.
Our Website uses the following Cookie types:
Technical Cookies are required to allow the User to use different options or services offered in the Website. If these Cookies are disabled, you will not be able to properly receive our contents or services.
Analytics Cookies, these Cookies are used to tracking and analysing user’s behaviour. If these Cookies are disabled, the Website will continue functioning, notwithstanding the information collected by these Cookies allows us to improve our Website.
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Cookie Type |
Description |
Examples |
Third party services |
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NECESSARY |
These Cookies are essential to improve your navigation experience and the proper functioning of our websites.
The Cookies are essential for remembering previous settings so you do not have to reconfigure them every time you visit us. |
-Volume settings. -Data transmission speeds. -Personalised contents adapted to your navigation |
[To complete by IT*] |
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LOG |
These Cookies are created when you register or log in into our Website.
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-You can keep your account logged even if you close your browser, so if you return to the website you will keep authenticated, unless you log off -Gain access to private zones of our website. |
[To complete by IT*]] |
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ANALYTICS |
These Cookies collect information related to your navigation experience in our websites anonymously.
We are able to quantify how many visitors reach the website or the most viewed contents. |
We can know if the user who is accessing is new or repeats visit.
-With that information we can improve your navigation experience. |
[To complete by IT*]] |
When do I consent to the use of cookies?
When you reach our Website and before starting your navigation, you will be warned about the use of Cookies, by clicking “accept”, closing the banner and using the Website or continue navigating in a way that implies a tacit consent, you provide consent related to our Cookies Policy. If you do not accept the use of Cookies you must stop navigating and leave the Website or follow the browser instructions to disable Cookies, as explained below.
How may I disable and block cookies?
At any time the User will be able to disable Cookies and continue navigating, although navigation will be limited and could be blocked at some point. The User may be able to block or disable them in the browser settings, which permits to reject the installation of all the Cookies or part of them. Most browsers allow the possibility of informing of the existence of Cookies or reject them automatically. If you reject Cookies, you will be able to continue using our Website, although some functionality will be limited negatively impacting on your experience in our Website.
In order to not being tracked by Google Analytics in the different websites, visit the following link:
https://tools.google.com/dlpage/gaoptout?hl=es.
Unless you have adjusted the settings of your browser, our systems will create Cookies when you visit our Website and accept our Cookies Policy. Please note that all browsers allow the possibility of adjusting their settings for that matter.
In order to obtain more information related to the way of adjusting the settings of each browser, please visit the following links:
Internet Explorer:
http://support.microsoft.com/kb/196955
http://support.microsoft.com/kb/283185
http://www.allaboutcookies.org/manage-Cookies/internet-explorer7- plus.html
http://www.allaboutcookies.org/manage-Cookies/internet-explorer8- plus.html
http://windows.microsoft.com/is-IS/windows7/How-to-manage-Cookies-in-Internet-explorer-9
Firefox:
http://support.mozilla.org/en-US/kb/cookies
Chrome:
http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647
Safari:
http://support.apple.com/kb/PH5042
iOS:
http://support.apple.com/kb/HT1677)
How may I revoke my consent?
The User will be able, at any moment, to revoke his consent related to use of Cookies, in order to do so the User will have to delete all Cookies stored in his computer or mobile device through the settings menu of his Internet browser.
Nevertheless, we inform you that deleting or disabling Cookies may affect to the functionalities of our Website and limit your access to certain areas or services provided through the Website.