BEPHARBEL MANUFACTURING SA PRIVACY POLICY
This Application collects certain Personal data from Users.
OWNER AND DATA CONTROLLER
BePharBel Manufacturing SA, 13 rue du Luxembourg à 6180 Courcelles, Belgium (No. BCE 0844.689.955). Data owner contact e-mail: info@bepharbel.com
TYPES OF DATA COLLECTED
The following feature among the types of Personal data collected by this Application or via third parties: Cookies, Utilisation data, first name(s), surname, gender, telephone number, company name, e-mail address, post code and town/city.
The full details regarding each type of Personal data collected are provided in the sections devoted to this privacy policy or in specific explanatory texts published before collection of the data.
The Personal data may be freely provided by the User or, in case of Utilisation data, collected automatically when you use this Application.
Unless otherwise stated, all the Data requested by this Application is mandatory and its absence may render it impossible to provide the Services via this Application. In the case where this Application specifies that certain data is not mandatory, the Users are free to refrain from disclosing such data, without there being any consequences regarding the availability or operation of the Service.
The Users who have doubts about the mandatory Personal data are invited to contact the Data owner.
Any use of Cookies – or other tracking tools – by this Application, or by the owners of third party services used by this Application, is aimed at providing the Service requested by the User, in addition to the other purposes set out in this document and in the Cookies policy, if such a policy is available.
The Users are responsible for any third party Personal data obtained, published or transmitted by means of this Application and must confirm that they have obtained consent from the third party to supply the data to the Data owner.
METHOD AND LOCATION OF PROCESSING
PROCESSING METHODS
The Data owner shall take the appropriate security measures to prevent unauthorised access, disclosure, alteration or destruction of the Data.
The Data is processed using computers or software tools, following procedures and organisational methods closely linked to the indicated purposes. In addition to the Data owner, the Data may be accessible, in some cases, to certain categories of person in charge of operations for this Application (such as administration, sales, marketing, legal affairs, system administration) or to external parties (such as third party technical service providers, messaging services, hosting providers, computer companies and communications agencies) designated, where applicable, as Processors by the Data owner. The up-to-date list of such parties may be requested from the Data owner at any moment.
The Data owner may be required to transmit the Data to the public authorities, in response to legal requests, including meeting requirements pertaining to national security or enforcement of the law.
LEGAL BASIS FOR PROCESSING
The Data owner can process the Personal data regarding the Users if one of the following conditions is applicable:
- The Users have given their consent for one or more of the specific purposes. It should be noted that, under certain legal systems, the Data owner may be authorised to process the Personal data until the User objects thereto (“opt-out”), without having to depend on the consent or one of the following items of legal basis. However, this condition is not applicable when the processing of Personal data is governed by European data protection law.
- The provision of Data is necessary for the performance of an agreement with the User or for any of the latter’s pre-contractual obligations.
- The processing is necessary in order to comply with a legal obligation which the Data owner must fulfil.
- The processing is linked to a task carried out in the public interest or in the exercise of official authority attributed to the Data owner.
- The processing is necessary for legitimate interests pursued by the Data owner or a third party.
In all cases, the Data owner will willingly assist you in clarifying the specific legal basis applicable to the processing and in particular whether the provision of Personal data is a legal or contractual requirement, or a requirement necessary for the conclusion of a contract.
PROCESSING LOCATION
The Data is processed at the head office of the Data owner and in all the other locations where the parties in charge of the processing are situated depending on the User’s location. Data transfers may lead to the transfer of the User’s Data to another country other than his or her own. To find out more about the processing location for such transferred Data, Users may consult the section containing details on the processing of Personal data.
For the necessities of some processing, certain data is transferred outside the European Union.
We transfer your Personal data and/or grant access to it to a Processor, service provider or third party located in non-Member States of the European Union solely when:
- It is located in a State that provides an adequate level of protection pursuant to an adequacy decision taken by the European Commission.
- Appropriate guarantees have been implemented in compliance with the GDPR, such as, for example:
- Signature of standard contractual clauses adopted by the European Commission for the transfer of Personal data to Processors established in third party non-Member State countries (2010/87/EU).
- The use of approved binding corporate rules.
- The application of an approved code of conduct.
Today, the only data that we transfer outside the European Union are those processed by one of our service providers, situated in a State which ensures an adequate level of protection pursuant to an adequacy decision taken by the European Commission:
Any transfer of Personal data to a country located outside the European Union will cease immediately if the adequacy decision or any other equivalent guarantee on which this transfer is based is invalidated or if it no longer satisfies the conditions.
To obtain more information and/or a copy of the guarantees implemented, all you need to do is send an e-mail to us at info@bepharbel.com, stating your surname, first name(s) and specify the subject “Transfers outside the European Union: personal data”. In the main body of your message, do not forget to state the exact information that you wish to request.
DATA RETENTION TIME
The Personal data is processed and retained for as long as is required for the purpose for which the data is collected.
As a result:
- Personal data collected for purposes linked to the performance of a contract between the Data owner and User must be retained until complete performance of the contract.
- Personal data collected for purposes of legitimate interest to the Data owner must be retained for as long as is necessary to achieve such objectives. The Users can find specific information concerning the legitimate interests pursued by the Data owner in the corresponding sections of this document or by contacting the Data owner.
The Data owner may be authorised to retain the Personal data for a longer period each time the User has given his or her consent for such processing, on the condition such consent is not withdrawn. Additionally, the Data owner can be obliged to retain the personal data for a longer period each time it is required for fulfilment of a legal obligation or by order of the authorities.
Once the retention period has expired, the Personal data shall be deleted. Consequently, the right to access, delete, and rectify the data as well as the right to data portability cannot be applied after expiry of the retention period.
PURPOSES OF THE PROCESSING
The data related to the User is collected in order to allow the Data owner to provide its Services, as well as for the following purposes: contacting the User, managing contacts and sending of messages, managing landing pages and invite pages, platform and hosting services and, where applicable, re-marketing.
The Users may find further information on the purposes of the processing and on the specific Personal data used for each purpose in the respective sections of this document.
DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA
The Personal data is collected for the following purposes, using several services:
CONTACTING THE USER
CONTACT FORM (THIS APPLICATION)
By filling in the contact form with his or her Data, the User authorises the use of such information by this Application in order to meet requests for information, quotations, or any other request as indicated on the header of the form.
Personal data collected: e-mail address, postal address, surname, first name(s), company name, telephone number, town/city and country.
In the case of Personal data processing for pharmacovigilance purposes, data identifying the occupation of the rapporteur and the patient are also collected (initials, date of birth, gender, age, patient who is breast-feeding or pregnant).
DISTRIBUTION LIST OR NEWSLETTER
Subscribing to the distribution list or the newsletter leads to the User’s e-mail address being added to the contact list of people who may receive e-mails containing commercial or promotional information concerning this Application. Your e-mail address may also be added to this list if you subscribe to this Application after having carried out a purchase.
Personal data collected: e-mail address, surname, first name(s), company name.
MANAGING CONTACTS AND SENDING MESSAGES
This type of service makes it possible to administer a database of e-mail addresses, telephone numbers or any other contact details for communicating with the User.
USER’S RIGHTS
The Users may exercise certain rights concerning their Data that is processed by the Data owner.
In particular, the Users have the right to do the following:
- Withdraw their consent at any moment. The Users have the right to withdraw their consent if they have already given their consent for processing of their Personal data.
- Object to processing of their Data. The Users have the right to object to the processing of their Data if the processing is carried out under a legal basis other than consent. Precisions are given in the relevant section hereafter.
- Access their Data. The Users have the right to know if their Data is processed by the Data owner, to obtain information on certain aspects of the processing and to receive a copy of the Data undergoing processing.
- Check and obtain rectification. Users have the right to check the accuracy of their Data and to request for it to be updated or corrected.
- Restrict the processing of their Data. The Users have the right, under certain conditions, to limit the processing of their Data. In such a case, the Data owner shall process their Data for storage purposes only.
- Have their Personal data deleted or wiped. The Users have the right, under certain conditions, to ensure that the Data owner deletes their Data.
- Retrieve their Data and transfer it to another Data controller. The Users have the right to retrieve their Data in a commonly used, machine-readable structured format and, if it is technically possible, to transmit it to another Data controller without obstacles of any sort. This provision is applicable, on the condition that the Data is processed by automated means and that it is based on the User’s consent to a contract to which the User is a party or to pre-contractual obligations.
- File a complaint. Users have the right to file a complaint with the competent authority for data protection.
INFORMATION CONCERNing the right to object to processing
When Personal data is processed in the public interest, in the exercise of a public authority attributed to the Data owner or for legitimate interests pursued by the latter, the Users may object to such processing by providing a reason related to their specific situation and must justify such a reason.
The Users should know that if their Personal data is processed for direct marketing purposes, they may object to such processing at any moment, without having to provide justification. To find out whether the Data owner is processing Personal data for direct marketing purposes, the Users can consult the relevant sections of this document.
HOW TO EXERCISE THESE RIGHTS
Any request by a User to exercise his or her rights maybe sent to the Data owner thanks to the contact details supplied in this document, in particular the e-mail address info@bepharbel.com. This request can be exercised free of charge and will be examined by the Data owner as soon as possible and always within a maximum period of one month.
COOKIE POLICY
This web site uses cookies – small text files that are placed on your machine in order to help the site to provide a better user experience. In general, the cookies are used to record the User’s preferences, store information for things such as shopping baskets and supply anonymised tracking data to third party applications such as Google Analytics. As a general rule, the cookies will provide a better browsing experience. However, if you so wish, it is possible for you to deactivate the cookies on this web site and others. The most efficient means of doing so is to deactivate the cookies in your web browser.
ADDITIONAL INFORMATION ON DATA PROCESSING AND COLLECTION
LEGAL ACTION
The User’s Personal data may be used for legal purposes by the Data owner before the courts or in proceedings that may lead to legal action arising from the inappropriate use of this Application or the related Services.
The User acknowledges that the Data owner may be required to reveal Personal data at the request of the public authorities.
ADDITIONAL INFORMATION CONCERNING THE USER’S PERSONAL DATA
In addition to the information contained in this privacy policy, this Application can provide the User with additional information and contextual information concerning specific services or regarding the collection and processing of Personal data.
It is your responsibility to regularly update your Personal data contained in the Data owner’s system. However, the Data owner may, from time to time, ask the User to update his or her data.
SYSTEM LOGS AND MAINTENANCE
For operational and maintenance purposes, this Application and any third party service may collect files that record the interactions with this Application (system logs) or use other Personal data for this purpose (such as IP addresses).
INFORMATION NOT INCLUDED IN THIS POLICY
Further information concerning the collection or processing of Personal data may be requested from the Data owner at any moment. Please consult the contact details featured at the beginning of this document.
HOW “PRIVATE NAVIGATION” REQUESTS ARE DEALT WITH
This Application does not accept “private navigation” requests.
Refer to the privacy policies of third party services to determine whether or not they accept “private navigation” requests.
MODIFICATIONS TO THIS PRIVACY POLICY
The Data Owner reserves the right to make modifications to this privacy policy, at any moment, by informing its Users via this page and possibly via the Application or – if it is technically and legally possible – by sending a notification to Users by means of the contact details available to the Data owner. It is strongly recommended to consult this page frequently and to check the date of the most recent modification indicated at the bottom of the page.
If the modifications influence the processing activities conducted on the basis of the User’s consent, the Data owner may ask the User, when necessary, for further consent.
DEFINITIONS and legal references
personal data (Or data)
Any information which, directly, indirectly or in relation with other information – including a personal identification number – makes the identification or identifiability of a natural person possible.
UTILISATION DATA
The information collected automatically by this Application (or by third party services used by this Application), which may include IP addresses or the domain names of the computers used by the Users using this Application, the URI (Uniform Resource Identifier) addresses, query time, method used to submit the query to the server, size of the file returned, the numerical code indicating the status of the response from the server (successful, error, etc.), country of origin, characteristics of the User’s browser and operating system, various details concerning time per visit (e.g., time spent in each page in the Application) and the details regarding the path followed in the Application with a special reference to the sequence of pages visited, as well as other settings concerning the User’s operating system or IT environment.
USER
The person using this Application who, unless otherwise stipulated, corresponds to the Data subject.
DATA SUBJECT
The natural person to which the Personal data refers.
PROCESSOR (OR DATA CONTROLLER)
The natural person or legal entity, public authority, institution or any other body which processes the Personal data on behalf of the Data controller, as described in this privacy policy.
DATA CONTROLLER (OR DATA OWNER)
The natural person or legal entity, public authority, institution or any other body which, alone or jointly with others, determines the purposes and means for processing the Personal data, including the security measures relating to the operation and use of this Application. Unless otherwise mentioned, the Data controller is the Owner of this Application.
THIS APPLICATION
The means via which the User’s Personal data is collected and processed.
SERVICE
The service provided by this Application as described in the related terms and conditions (where applicable) and on this web site/in this application.
EUROPEAN UNION (OR EU)
Unless otherwise specified, all the references made to the European Union in this document include all the current Member States of the European Union and the European Economic Area.
COOKIES
Small series of data stored on the User’s device.
LEGAL NOTICES
This privacy policy was prepared pursuant to the provisions of several pieces of legislation, in particular, article 13/14 of European regulation 2016/679 (the general data protection regulation).
This privacy policy solely concerns this Application, unless otherwise specified in this document.
Most recent modification: 13th October 2020