Last update: July 2018
Almirall, S.A. (“Almirall“, “we“, “us“, “our“) is committed to the safeguard of the privacy of its stakeholders and the compliance of the data protection principles and applicable laws.
To obtain more information about this document or about how we process your personal data, you can contact our Global Data Protection Officer at the e-mail address firstname.lastname@example.org.
1. Who is the controller of the data you provide?
For the purpose of the General Data Protection Regulations and any local applicable laws, the data controller of the data you provide through this Site is Almirall, S.A., a Spanish company with registered office at Ronda General Mitre 151, 08022 Barcelona, with VAT number A-58869389, registered at the Companies Registry of Barcelona at Volume 21795, Sheet 32, Page no. B-28.089 and with the Ministry for Health and Consumer Affairs Registration Number – 1889E
You can contact Us at the telephone number (+34) 93 291 30 00
Please note that data controller means the legal entity that decides the purposes and means of processing your personal data.
2. What kind of personal data we process?
We may collect and process the following data about you:
- Information you give us. You may give us information during your registration process in the Site or whenever you fill in a form which is necessary in addition to such register, whenever you edit your personal profile and/or when you report a problem with our Site.
In each case, we try to limit to collect the necessary information we need for the purposes to process your request in each case. The information you give us may include your name, address, e-mail address, country, specialty, work centre and phone number.
- Information we collect about you. As you navigate around the Site, certain information can be passively collected (that is, gathered without you actively providing the information), using various technologies. We and our third-party service providers passively collect and use information in a variety of ways, including the following:
- Through your browser: The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are: browser type and browser version, operating system used, deferrer URL, host name of the accessing computer, time of the server request and IP address
Information gathered through cookies will be processed in aggregate unless you give us specific consent to link it to your profile by accepting to receive customized interaction with you as more fully explained in section 3.2) below.
Except where expressly stated, the provision of your personal data is voluntary and does not affect the quality or use of the services offered by Almirall. However, missing or incorrect mandatory personal data may make it impossible for Almirall to provide the services you have requested.
3. For what purposes do we need your personal data?
Your personal data will be used for different purposes as follows:
- Improve your user experience and have a customized interaction with you by combining data of your activity, interests and preferences, your navigation habits and behaviours, collected in the platform or gathered from internal and external sources. Please see our Cookies Policy for more information, especially the section related to the tracking tools.
- To provide you with communications or news about Almirall activities, products and services, through any channel (e-mail, post mail, telephone, and others). This information may include those of Almirall affiliates belonging to the same group of companies. You can find more information about our affiliates at www.almirall.com. Such communications, which might be commercial communications, will or might be customised and addressed to you in attention to the information you have voluntarily provided to us through the registration process or from internal sources. If you give us your consent to the purposes indicated in section 3.2) above, we might combine such information with your navigation habits and behaviours, collected in the platform or gathered from internal and external sources.
Your personal data will not be used for any other different purposes.
4. How long will we keep your personal data?
5. What is our lawfulness to process your personal data?
The processing of your personal data for the purposes indicated above is based on your specific consent. If you use the Site without register and log in, the lawfulness lies on the legitimate interest we have to run the Site and the performance of a contract or pre-contractual measures.
6. Who do we share your personal data?
Data will not be shared with third parties other than our services providers who help us to better provide you with the services related to almirallMed and to make direct marketing based on your profile (i.e. agencies that help us to organise events, for digital campaigns, data analytics, amongst others), (hereinafter, the “Recipients“).
Whenever information needs to be transferred to Recipients outside the European Economic Area to a country which has not received the decision of adequate level of protection issued by the European Commission, personal data will be duly protected by standard contractual clauses approved by the European Commission, the relevant Privacy Shield certification or binding corporate rules of the data processor.
7. What are your rights as data subject and how you can exercise them?
You may exercise at any time any of the following rights before Almirall in connection with the processing of your personal data:
- Right of access: means the right to obtain access to your information that Almirall processes.
- Right to rectification: means the right to be entitled to have your information corrected if it is inaccurate or incomplete.
- Right to erasure: in simple terms, it means to request the deletion or removal of the information concerning him/her where there is no compelling reason for an organisation to keep using it. This right is also known as “the right to be forgotten” and is not a general right to erasure; there are exceptions.
- Right to restrict processing: means the right to ‘block’ or suppress further use of the information concerning You in certain circumstances. When processing is restricted, we inform you that Almirall can still store your information, but may not use it further.
- Right to data portability: means the right to obtain and reuse personal data by a third party in a structured, commonly used and machine readable format in certain circumstances. If you request the direct transfer of the data to another data controller, this will only take place if it is technically feasible.
- Right to object: means the right to object to certain types of processing, in certain circumstances.
The lawfulness of the data processing up to your consent withdrawal remains unaffected by the revocation.
If you would like to exercise any of the abovementioned rights, you can send us an electronic request to our address email@example.com, attaching a copy of your personal ID card/passport.
Finally, we inform you that you can contact the Spanish Data Protection Agency or any European supervisory entity for any claim arising from the processing of your personal data. You can find an updated list of these organizations by jurisdiction in https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm