The company Fulton Medicinali S.p.A. (hereinafter “Fulton” or “Owner”), pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data (hereinafter “GDPR”, from the English “General Data Protection Regulation”) and Legislative Decree 196/2003 (Privacy Code), provides you with the following information on the processing of your personal data.
Identity and contact details of the data controller
The Data Controller is Fulton Medicinali S.p.A., with registered office in Via G. Marconi n. 28/9, 20044 – Arese (Milan), Italy, e-mail: firstname.lastname@example.org.
Purposes of the treatments and legal bases of the treatments
Your personal data will be processed, in compliance with current legislation, in a correct, lawful and transparent way for the purposes listed below and according to the following assumptions of lawfulness (legal bases of treatment).
Purposes of the treatment Legal bases of the treatment
- a) Correct and complete management of your eventual request (for example, your request for information or assistance, by filling out the contact form) [management of requests]. The processing of your personal data for this purpose is necessary for the performance of a contract or the execution of pre-contractual measures (herein to be understood as a “legal relationship” established between you and the Controller as a result of your possible request) (art. 6.1.b, GDPR) and therefore does not require your consent.
- b) Correct and complete management of reports relating to pharmacovigilance [pharmacovigilance].
For general information on the processing of personal data in the context of activities related to pharmacovigilance visit the Specific Information [link]. The processing of your personal data for this purpose is a legal obligation (Art. 6.1.c, GDPR) and therefore does not require your consent.
- c) Correct and complete management of your registration to the area reserved for pharmaceutical companies or operators/pharmaceutical representatives interested in the products of the Owner (also with a view to marketing) accessible through a link on the site (so-called “Reserved”) and use by you of the content and services reserved for registered users [registration to the reserved area and use of the related content and services].
The processing of your personal data for this purpose is necessary for the performance of a contract or the execution of pre-contractual measures (i.e. the General Terms and Conditions of the Reserved Area which govern the registration to the Reserved Area and the use of its contents and services) (art. 6.1.b, GDPR) and therefore does not require your consent.
Categories of processed data
The Owner will process the following categories of personal data concerning you:
- personal data: name and surname and contact data, such as electronic mail address (e-mail), telephone number;
- f you are a registered user, name and surname and contact data, such as e-mail address, telephone number, company, username and password for access to the Reserved Area, as well as data necessary or related to the use of specific content and services within the Reserved Area;
- personal data used by you for a possible request (in particular, name and surname, company, VAT number, e-mail address), as well as any further personal data you may provide in your contact request, for the management of your request.
Your personal data will be obtained by the Controller:
- directly from you and from your interaction with us.
Nature of the conferment
The provision of your personal data for the management of your contact requests is a necessary requirement for the Owner to be able to follow up on your possible request: failure to provide it would make it impossible for you to see your request followed up.
The provision of your personal data for pharmacovigilance purposes is a legal obligation and therefore does not require your consent.
The provision of your personal data for registration to the reserved area and use of related services is a contractual obligation: failure to provide it would make it impossible for you to register to the reserved area and to use the content and services reserved for registered users.
The processing of your data will be carried out using automated and non-automated tools, with logic strictly related to the purposes of treatment and, in any case, with methods and procedures to ensure the security and confidentiality of data.
Categories of recipients of personal data
For the purposes indicated above, your personal data may be communicated
- to persons authorized by the Data Controller to carry out personal data processing operations (workers or collaborators of the Data Controller);
- to data processors appointed by the Data Controller (e.g. suppliers of IT, technological and telematic services; suppliers of services for the management and storage of tax and accounting documents);
- to autonomous data controllers (for pharmacovigilance: national and European medical and pharmaceutical agencies, other pharmaceutical companies linked to the Data Controller by licensing and distribution contracts for pharmaceutical products or in the event of transfer of marketing authorisation for the pharmaceutical product; for communications: providers of telecommunications and web-based communication services).
Your data may also be transmitted, in accordance with the law, to the tax authorities, the police and judicial and administrative authorities, for the detection and prosecution of crimes, the prevention and protection from threats to public safety, to allow the Controller to ascertain, exercise or defend a right in court, as well as for other reasons related to the protection of the rights and freedoms of others.
Period of data retention
We keep your personal data for a limited period of time, depending on the purpose of processing. After this period, your data will be permanently deleted or otherwise irreversibly anonymized.
Your personal data will be stored in accordance with the terms and criteria specified below:
- for the management of your requests for a period of 2 (two) years from the complete and correct management of your request;
- for pharmacovigilance until the pharmaceutical product is authorized for marketing and for a further period of 10 (ten) years from the expiry of the marketing authorization;
- for the registration to the reserved area and use of the relative contents and services, if you are a registered user, until the cancellation of your account, which you may request at any time by contacting the Owner. During the registration phase, the verification of your status as a professional in the pharmaceutical sector will last for a maximum of 30 (thirty) days; if the verification is not carried out within this period of time, your personal data will be deleted from our databases and your registration request will be considered unsuccessful.
This is without prejudice to cases in which storage for a later period is required for litigation, requests by competent authorities or under applicable law.
Extra EU/EEA transfer of personal data
Your personal data may be transferred to countries outside the European Union (EU) or the European Economic Area (EEA) which nonetheless offer an adequate level of data protection, as established by decisions of the European Commission (https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en).
The transfer of your personal data to countries that do not belong to the EU/EEA and that do not ensure adequate levels of protection will only be carried out after the conclusion between the Data Controller and the recipient of the data of specific agreements, containing appropriate safeguards and guarantees for the protection of your personal data so-called “standard contractual clauses”, also approved by the European Commission, or if the transfer is necessary for the conclusion and execution of a contract between you and the Data Controller or for the management of your requests.
Rights of the interested party
As data subject you may exercise, in relation to the data processing described herein, the rights provided for by the applicable legislation on the protection of personal data, therein you have the right to obtain
- confirmation of the existence or otherwise of personal data concerning you;
- information about the origin of your personal data;
- information about the purpose and method of processing of your personal data;
- information about the logic applied in case of treatment with the aid of electronic instruments;
- the identification details of the data controller and data processors;
- an indication of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity, for example, as data processors;
- when possible, information about the storage period and obtain limitations to the processing;
- the portability of the data, i.e. receive them in a structured format for common use and readable by automatic devices and transmit them to another data controller without hindrance
- the updating, rectification or integration of your personal data;
- the cancellation, transformation into anonymous form or blocking of your personal data, processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected;
- revoking your consent to the processing at any time.
- to lodge a complaint with a supervisory authority (art. 77) or take legal action (art. 79), if you believe that the processing of your data violates the European Regulation. The complaint may be lodged in the Member State in which you normally reside or work or in the place where the alleged infringement occurred.
To exercise these rights you may contact the Data Controller at any time by writing to Fulton Medicinali S.p.A., with registered office in Via G. Marconi n. 28/9, 20020 – Arese (Milan), Italy, or at the e-mail address: email@example.com.
Modifications to the present informative report