1. The Privacy Policy of the website of EUROPHARMA ALLIANCE SP. Z O.O. (hereinafter: the “EuroPharma Alliance Website”) is for information purposes only and does not give rise to any obligations on the part of Visitors.
2. The controller of personal data processed via the EuroPharma Alliance Website is EUROPHARMA ALLIANCE spółka z ograniczoną odpowiedzialnością (a limited liability company under Polish law), with its registered office in Rzeplin at al. LED 1, 55-020 Rzeplin, Poland, entered in the Register of Entrepreneurs of the National Court Register (KRS) by the District Court for Wrocław-Fabryczna in Wrocław, 6th Commercial Division of the National Court Register, under KRS number 0000286948, NIP (tax identification number) 8942915092, e-mail: office@pharmaalliance.eu (hereinafter: the “Controller”).
3. The personal data of a Visitor who discloses it by accessing the EuroPharma Alliance Website or by entering it on a page of the EuroPharma Alliance Website is collected and processed in accordance with applicable law, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation, GDPR), taking into account the Corrigendum of 23 May 2018 (OJ EU L 127, p. 2) and the Corrigendum of 4 March 2021 (OJ EU L 2021 No 74, p. 35), and the Polish Act of 10 May 2018 on the Protection of Personal Data.
4. The Controller processes the Visitor’s data comprising: e-mail address, IP address, domain name, browser type, operating system type and other data disclosed by the Visitor at his or her discretion by entering it on a page of the EuroPharma Alliance Website (e.g. first name, surname, company (name), telephone number).
5. The Controller processes in particular the e-mail address provided by the Visitor for the purposes set out in Article III below, including for sending the Visitor information for the purposes of direct marketing of products or services of the Controller or of third parties, including entities related to the Controller. By entering his or her personal data, including the e-mail address, on the EuroPharma Alliance Website, in particular in the field marked “e-mail”, the Visitor consents to the processing of his or her personal data for the purpose of receiving commercial and marketing information by electronic means. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before its withdrawal. Providing data is voluntary, but it is necessary in order to receive commercial and marketing information about the services of the Controller or of third parties, including entities related to the Controller.
6. The Controller processes the Visitor’s data on a legal basis and lawfully, fairly and in a manner transparent to the Visitor, for specific purposes and not “in reserve”, no more than necessary and for no longer than necessary, taking care to ensure that the data is accurate and ensuring appropriate data security.
7. The term “EuroPharma Alliance Website” means a set of web pages and other documents made available on the Internet for the purpose of presenting the goods and services of EuroPharma Alliance sp. z o.o., conducting marketing activities, establishing contact with persons interested in cooperating with the Company or in purchasing, having delivered or using the goods or services of the Company or of entities related to it, presenting information relating to the Company’s activities, and for the proper performance of any contractual obligations.
II. STATUS OF THE VISITOR AND TYPES OF DATA COLLECTED BY THE CONTROLLER
1. A Visitor is any person browsing the web pages of the EuroPharma Alliance Website.
2. While a Visitor browses the web pages of the EuroPharma Alliance Website, data concerning the Visitor is collected automatically. This data includes: IP address, domain name, browser type and operating system type. This data may be collected by means of cookies. Detailed information on the cookies used, including their scope, type and manner of use, as well as the rights and obligations of the Visitor, is set out in the Cookie Policy in Article VIII below.
3. The Controller also processes anonymised operational data, other than that collected by cookies, relating to the use of the EuroPharma Alliance Website (IP address, domain) in order to generate statistics used in administering the Website; the data collected is aggregated and anonymous, i.e. it does not contain features identifying Visitors to the EuroPharma Alliance Website. This data is not disclosed to third parties.
4. For statistical purposes, the EuroPharma Alliance Website is integrated with its own statistics system and with the statistical mechanisms of Google Analytics.
III. PURPOSES AND LEGAL BASES OF THE PROCESSING OF PERSONAL DATA
The Controller processes Visitors’ personal data because it is necessary for the following purposes:
in order to respond to enquiries and to conduct further correspondence with persons representing or acting on behalf of the Controller’s customers, suppliers and potential business partners, which is a legitimate interest of the Controller (legal basis: Article 6(1)(f) GDPR);
in order to take steps necessary prior to entering into a contract or to perform a concluded contract, including to carry out cooperation or the sale of goods, delivery of goods or provision of services covered by the contract (legal basis: Article 6(1)(b) GDPR);
in order to survey the satisfaction of customers (whose data is processed) and to assess the quality of our service, which is our legitimate interest (legal basis: Article 6(1)(f) GDPR);
in order to establish, pursue or defend against possible claims, which is a legitimate interest of the Controller (legal basis: Article 6(1)(f) GDPR);
for archiving purposes, to safeguard information in case of a legal need to demonstrate facts, which is a legitimate interest of the Controller (legal basis: Article 6(1)(f) GDPR);
in order to comply with legal obligations arising from tax and fiscal law (legal basis: Article 6(1)(c) GDPR);
in order to present commercial and marketing information of the Controller to the telephone number provided by the data subject, i.e. to offer products and services (direct marketing) of the Controller or of a third party, including entities related to the Controller (legal basis: Article 6(1)(a) GDPR, in accordance with Article 398(1) of the Polish Electronic Communications Law);
in order to present commercial and marketing information of the Controller to the e-mail address provided by the data subject, i.e. to offer products and services (direct marketing) of the Controller or of a third party, including entities related to the Controller (legal basis: Article 6(1)(a) GDPR, in accordance with Article 398(1) of the Polish Electronic Communications Law).
IV. INFORMATION ON THE VOLUNTARY NATURE OF PROVIDING DATA
By proceeding to the EuroPharma Alliance Website by clicking the “I consent” link, the Visitor voluntarily consents to the processing of his or her personal data by the Controller. Providing data is voluntary, but it may prove necessary for the proper display and use of the EuroPharma Alliance Website and for possible contact with the Controller. Failure to provide data may make it impossible to respond to the Visitor’s enquiry, to establish cooperation or to receive commercial information.
V. TRANSFER OF PERSONAL DATA
1. The Controller may transfer personal data to the following categories of recipients:
entities whose services the Controller uses in the processing of data, i.e. companies providing the Controller with telecommunications, IT, legal, financial, tax advisory and accounting services, entities providing advisory and training services, and entities archiving or deleting data;
entities involved in the performance of a contract, in particular entities related to the Controller;
entities providing marketing services;
law enforcement authorities, judicial authorities, public administration bodies, as well as services, inspectorates and guards performing tasks specified by law.
2. As a rule, the Controller does not transfer the personal data it obtains outside the EU/European Economic Area or to international organisations. However, in connection with the use of tools of the providers listed in Article X(5) (including Google, LinkedIn, HubSpot, Microsoft and Anthropic), data may be transferred to third countries, including the United States, on the basis of a European Commission decision finding an adequate level of protection (including under the EU-U.S. Data Privacy Framework) or on the basis of standard contractual clauses. The Visitor may obtain a copy of the safeguards by contacting the Controller.
VI. RETENTION PERIOD OF PERSONAL DATA
The Controller processes Visitors’ data obtained for the purposes specified in Article III above for the period necessary to safeguard the Controller’s rights and claims. The retention periods for the data of contact persons of customers, suppliers and potential business partners are set out in Article IX(5).
VII. RIGHTS OF DATA SUBJECTS
1. Visitors have the following rights:
the right of access to their data and to receive a copy of it,
the right to rectification (correction) of their data,
the right to erasure of data,
the right to restriction of processing,
the right to object to the processing of data,
the right to data portability,
the right to lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych),
the right to withdraw consent to the processing of personal data at any time, without affecting the lawfulness of processing carried out before its withdrawal.
2. The Visitor has the right to object, on grounds relating to his or her particular situation, to processing of data based on the Controller’s legitimate interest (Article 6(1)(f) GDPR). The Visitor may at any time object to the processing of his or her data for direct marketing purposes; following such an objection, the data will no longer be processed for that purpose.
3. The Visitor exercises the above rights by submitting a request to the Controller by sending an appropriate message in writing or by e-mail to the Controller’s address indicated at the beginning of this Privacy Policy, by telephone on: +48 717 259 066, or directly at the Controller’s registered office.
VIII. COOKIE POLICY
1. Cookies are IT data, in particular small pieces of information in the form of text files, intended for use with websites, sent by the EuroPharma Alliance Website and stored on the side of the person visiting the EuroPharma Alliance Website, kept on the Visitor’s end devices (e.g. on the hard drive of a computer or laptop or on the memory card of a smartphone – depending on the device the Visitor uses to access the EuroPharma Alliance Website).
2. Consent by Visitors to the storage of cookies is voluntary, but it may prove necessary for using the EuroPharma Alliance Website or for contacting the Controller.
3. The Controller may process data contained in cookies while Visitors use the Website for the following purposes:
to enable the basic functionalities of the EuroPharma Alliance Website, such as access to secure areas of the website; without these cookies the website used by the user may not display correctly,
to adapt the content of the EuroPharma Alliance Website to Visitors’ individual preferences (e.g. regarding colours, font size, page layout) and to optimise the use of the EuroPharma Alliance Website, by registering Visitors’ choices (such as user name, language or the region in which users are located); these cookies may also be used to remember changes made by the Visitor, e.g. changes to the size and font of text and other parts of the website that can be edited. The Controller may use the information collected by cookies to identify user behaviour and to deliver content,
to compile anonymous statistics showing how the EuroPharma Alliance Website is used, by means of cookies collecting information on how the Visitor uses the website, including which parts of the website he or she visits most often and whether he or she receives page error messages.
4. The Visitor may determine the conditions for the use of cookies via the settings of his or her own web browser. This means that, for example, the storage of cookies may be partially restricted (e.g. temporarily) or disabled completely – in the latter case, however, this may affect some functionalities of the EuroPharma Alliance Website.
5. A Visitor to the EuroPharma Alliance Website may opt out of cookies via the settings of his or her own web browser. Web browser settings concerning cookies are relevant to consent to the use of cookies by the Controller – in accordance with the applicable regulations, such consent may also be expressed through web browser settings. If no such consent is given, the web browser settings concerning cookies should be changed accordingly.
6. Detailed information on changing cookie settings and on deleting cookies independently in the most popular web browsers is available in the help section of the web browser and on the pages below (simply click the relevant link):
in Internet Explorer
in Firefox
in Opera
in Chrome
in Safari
7. For statistical purposes, the EuroPharma Alliance Website uses cookies provided by, for example, Google AdWords and Google Analytics.
8. The Controller may use analytical and marketing tools to analyse how the Website is used, to measure the effectiveness of advertising activities and to improve its functionality. The analysis may include automated processing of information about user activity, including profiling consisting in assessing users’ potential interests. Tools requiring consent are used in accordance with the preferences expressed by the user via the cookie consent management mechanism.
IX. CONTACT PERSONS OF CUSTOMERS, SUPPLIERS AND POTENTIAL BUSINESS PARTNERS (ARTICLES 13 AND 14 GDPR)
1. This Article supplements the other provisions of the Policy with the information referred to in Articles 13 and 14 GDPR, addressed to natural persons who are customers, suppliers or potential business partners of the Controller and to persons representing such entities or acting on their behalf (e.g. employees, associates, designated contact persons), with whom the Controller communicates in connection with its business activities, in particular by e-mail or telephone.
2. The Controller processes the following categories of data: first name and surname, name of the represented entity, position held, business e-mail address and telephone number, content of correspondence, and, in the case of persons running a business, also the NIP (tax identification number) and the business address.
3. Source of data: the data comes from the data subject, from the entity that the person represents or on whose behalf he or she acts, or from publicly available sources (including trade fairs and conferences, business cards, websites, public registers such as the KRS and CEIDG, the LinkedIn service and other industry and professional portals).
4. The purposes and legal bases of processing are set out in Article III. With regard to contact persons, data is processed in particular for the purpose of conducting correspondence and business contacts, including presenting cooperation offers (Article 6(1)(f) GDPR). If the party to a contract is an entity represented by the contact person, that person’s data is processed in order to administer that contract on the basis of Article 6(1)(f) GDPR.
5. Retention period:
data processed for the purpose of conducting correspondence and presenting cooperation offers – until an objection is lodged; if cooperation is established, for the duration of that cooperation and thereafter until the limitation of claims;
data processed for the purpose of direct marketing – until an objection is lodged or consent is withdrawn.
6. Providing data is voluntary but, to the extent necessary for entering into and performing a contract or fulfilling legal obligations, it is a condition for their performance; failure to provide data may make it impossible to conclude or perform a contract.
7. The recipients of data and the transfer of data outside the European Economic Area are described in Article V. The rights of data subjects (including the right to object to processing for direct marketing purposes and the right to lodge a complaint with the President of the Personal Data Protection Office) and the manner of exercising them are described in Article VII, and the Controller’s details and contact information in Article I(2).
X. FINAL PROVISIONS
1. The provisions of this Privacy Policy of the EuroPharma Alliance Website are governed by Polish substantive and procedural law.
2. The Controller makes available, as appropriate, the following technical measures preventing unauthorised persons from obtaining and modifying personal data transmitted by electronic means:
protection of data against unauthorised access,
SSL certificate
3. The EuroPharma Alliance Website may contain links to other websites.
4. The Controller recommends that, after moving to other websites, Visitors read the privacy policy established there. This Privacy Policy applies only to the EuroPharma Alliance Website.
5. Information on the privacy policies of external providers:
