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PRIVACY POLICY

General

In this Privacy Policy, corresponding to the website http://chemovation.theoms.es (hereinafter, the “Website”), owned by Insud Pharma, SLU, (hereinafter, “Insud Pharma”) describes the way in which Insud Pharma process the personal data collected from users at the moment in which they register or browse the Website (hereinafter, the ¨Users¨). We ask Users to carefully read the following Privacy Policy as it contains relevant information on how we treat the personal information that you provide us or that we collect through the use of the Website.

Insud Pharma and all its subsidiaries located in Spain, EU or third countries are globally known as Insud Pharma Group (hereinafter, “Insud Pharma Group”). Please find additional information about Insud Pharma Group and a non-exhaustive list of Insud Pharma´s subsidiaries here.

Insud Pharma dedicates all its efforts to respect the privacy and security of the Users and undertakes to use personal data in accordance with the General Data Protection Regulation ("GDPR") and national data protection law.

Below are the identification details of the data controller and the Data Protection Officer.

Corporate name INSUD PHARMA S.L.U.
Registered office Calle Manuel Pombo Angulo, 28 3ª planta 28050 Madrid, España.
Tax Identification Number B85212165
Telephoneo +34 913021560
Email dataprotection@insudpharma.com
Companies House Information Registro Mercantil de Madrid, Hoja M-326179, Tomo 34641, Folio 10.

Categories of Personal Data and Purposes of the Processing

To use the services or functionalities of the Website, Users must provide us with their personal data in order to manage their registration, enrol them in certain services or properly manage their request. In addition to the information that is provided directly to Insud Pharma, we also collect certain information when you use the Website.

All personal data collected through the Website will be duly incorporated into databases under the responsibility of Insud Pharma. This treatment is duly registered in the Record of Processing Activities.

Likewise, we inform Users that the fields requested in the forms that are marked with an asterisk are mandatory. Thus, if the requested information is not provided, we will not be able to carry out the service.

Below, we have specified the personal data we collect, the purposes for which we use such personal data, and the length of time that we will generally keep your personal data:

• Participation in Chemovation Programme

Through the Website Insud Pharma organizes the "Chemovation" programme for all those Users who are interested in participating (hereinafter, the “Programme”). The Programme will be carried out in accordance with the legal bases made available to and accepted by Users prior to their participation.

To participate, User must register through the Website and fill in the form provided. Users will be asked to provide certain personal data during their register, which will be necessary to manage its correct participation in the Programme. This personal data may include, among others: name, surname, email, organisation or company and country.

Insud Pharma will process said personal data, voluntarily provided by the User, for their correct participation in the Programme. In the event of becoming the winner, Insud Pharma may require Users to provide additional data for the correct management and delivery of the prize. In addition, Insud Pharma may use and communicate User’s personal data and information related to their projects through the Website and social media, both internal or external, to promote and inform about the Programme carried out by Insud Pharma. When necessary, User’s images will be processed in accordance with the legal bases of the Programme.

During the participation it may be necessary to send Users communications to keep them informed about the progress of their participation in the Programme. These communications are necessary for the effective management of their participation.

The legal basis that legitimized the processing of such data is the execution of the legal bases of the Programme previously read and accepted by the participants at the time of their register. The personal data will be kept for as long as they are necessary to carry out this purpose, and once this purpose ends, they will be kept for the applicable statute of limitations and subsequently deleted.

Users may obtain more information about the processing of their data for this purpose in the Programme's legal bases.

The User undertakes to provide truthful and accurate data through the Website and their registration, so that Insud Pharma can duly monitor their participation. In the event of providing data of third parties, the user shall be responsible for informing those data subjects in relation to the processing of their data in accordance with the terms set out in this Policy and in the legal bases of the Programme.

• User’ Communications

This category includes any personal data provided by the User during their communications with Insud Pharma for the purpose of solving any query, suggestion or claim. In this sense, if the User has made any request or suggestion through our contact forms, we will process the personal data in order to answer it.

The legal basis for the processing of these personal data is consent when the Users provide their data through the contact forms.

• Information about your Access and use of the Website.

We collect certain information from Users automatically obtained from the use of the Website related to Users´ equipment or devices, their use and browsing habits.

This information may include data such as the language of the Users, pages, sections or functionalities of the Website they use, IP address, search engine used, date and time, etc. Insud Pharma can collect this information through the use of the cookies. For more information on how we use cookies, you can consult our Cookies Policy.

We use this personal data base don our legitimate interest in order to improve our products and services. We will keep personal data for 1 month from the last time you accessed the Website.

Insud Pharma may combine Users' personal data with other non-identifying information obtained by Users through the Website, as described above. In such cases, the combined information will be processed as personal data.

• Maintenance and optimization of the Website.

Users´ personal data will also be used for the maintenance and analysis of the Website, to solve performance problems, improve availability and protect the Website against fraud (i.e. in case of repeated attempts to log in) or against the breach of our terms and conditions. The analysis also allows us to check if the different online processes that we offer are working effectively so that we can improve, whenever possible.

The use of Users´ personal data for these purposes is based on our legitimate interest and will be kept for a maximum period of 6 months.

• Comply with our Legal Obligation

We may need to process your personal data to comply with legal obligations binding or accepted by us. Likewise, we may need to provide information to and as required by local law enforcement agencies, other government authorities, or otherwise required by law or to protect the rights and safety of our property, company, employees and customers.

How we Share Personal Data

Sometimes it is necessary to share your personal data with other Insud Pharma subsidiaries, companies of the Insud Pharma Group or third parties in order to guarantee the correct provision of the Website. We may share such information with the following:

  • Insud Pharma Group companies due to the use of shared computer systems, which may be located in the European Economic Area (EEA) or in third countries.
  • Service providers, as long as it is necessary for the provision of certain service, as data processor.
  • Insud Pharma’s social media profiles, where appropriate to promote and inform about activities and campaigns described herein.

Such entities may be located in Spain, other countries in the EEA or anywhere else in the world. When we keep personal data outside the EEA, we guarantee an adequate level of protection of the transferred data. To this purpose, we require service providers to take appropriate measures to protect the confidentiality and security of personal data.

For example, for services provided by providers outside the European Economic Area, we use Standard Model Clauses approved by the European Commission.

Insud Pharma may disclose User’s personal data to any public administration, when required by law and compelled to do so by such authorities. All data communications will always be carried out in compliance with the GDPR and the national data protection law.

Storage of Personal Data

We will keep your personal data for as long as you are a user of the Website and for as long as they are necessary to fulfil the purposes described herein. In any case, we will keep your personal data as long as you do not withdraw the consent previously granted.

Personal data collected through the use of cookies will be kept for the period of time indicated in the Cookies Policy. Once these periods have expired, your data will be deleted.

Security of the Personal Data

Insud Pharma cares about guaranteeing the security and confidentiality of Users´ personal data. To do this, the appropriate technical, physical and organizational measures are taken to protect the personal data collected through the use of the Website from the improper use, destruction, loss, alteration, disclosure, acquisition or accidental, illegal or unauthorized access, required in accordance with the provisions of the GDPR and current regulations on data protection.

However, no Internet-based site can be completely secure, therefore, we are not responsible for unauthorized for unintended access that is beyond our control It is the responsibility of the Users to control the security of their information. In this sense, Insud Pharma urges and encourages all Users to be careful when sharing information.

Insud Pharma will not control the content and information that Users decide to share with other Users and, therefore, Insud Pharma is not responsible for the consequences of their actions. Insud Pharma undertakes (i) to act quickly and responsibly in the event that the security of Users´ personal data is compromised and (ii) to report this, if applicable, with the utmost diligence.

In the event of a personal data violation, Insud Pharma undertakes to notify the Spanish Data Protection Agency, without undue delay, after becoming aware of said violation. Likewise, when the violation of personal data is likely to produce a high risk for the rights and freedoms of Users, Insud Pharma will notify Users of the violation of personal data and the measures adopted to mitigate the risks and effects that may occur.

Cookies

Much of the information referred to in this Privacy Policy is collected through the use of cookies. Cookies are small text files containing small amounts of information that are downloaded and can be stored on your user device, for example, your computer, smartphone or tablet. These cookies are sometimes necessary to remember your account settings, language and country, but they also allow us to track and analyse Users behaviour on our Website and to display personalised advertisements on our Website or on third party websites. Where necessary, you will be asked to consent to the use of cookies. To obtain additional information on how cookies are used in the Website and its deactivation please visit our Cookies Policy.

Minors

The Website is not intended to be used by persons under the age of 18. Under no circumstances personal data from minors will be voluntarily collected through the application unless prior authorized by their parents or legal guardian

Users Rights Concerning Data Protection

At any time, Users may exercise before Insud Pharma their data protection rights, in particular the right of access, rectification, restriction of processing, erasure, objection and portability pursuant to the applicable legislation. This means Users can ask what personal data we have about them, update, or they 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 among other.

In the event the User decides to object 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.

After the User exercises any of the abovementioned rights, and during Insud Pharma 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. In addition, Users may also lodge a claim before the Spanish Data Protection Agency (www.aepd.es) or the relevant data protection authority if they consider that we have not processed their personal data in accordance with the regulations.

Privacy Policy Updates

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.

Contact

If you have any further questions about the use of your personal data or about our Privacy Policy, you can contact Insud Pharma’s Group DPO by email through dataprotection@insudpharma.com.