When you link our Site, your browser will transfer certain data to our web server. This is done for technical reasons and required to make available to you the requested information. To facilitate your access to the Site, the following data are collected, briefly stored and used:
- Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;
- Date and time of access;
- Time zone difference to Greenwich Mean Time (GMT);
- Content of request (specific site);
- Status of access/HTTP status code;
- Transferred volume of data;
- Website requesting Access;
- Browser, language settings, version of browser software operating system and surface;
- Other unique identifiers, including mobile device identification numbers;
- Information collected through cookies and other technologies.
We may use first- or third-party cookies, and similar technologies to automatically collect this information.
Moreover, to protect our legitimate interests, we will store such data for a limited period of time in order to be able to initiate a tracking of personal data in the event of actual or attempted unauthorized access to our servers (Art. 6(1)(f) General Data Protection Regulation).
What you will find in this document
The objective of this Policy is to help you understand:
- Information we collect from you: what information Piauhy collects and processes about you.
- The purposes: for what reasons and purposes Piauhy processes your Personal Data.
- Why: on what basis does Piauhy process your Personal Data.
- Where from: from what sources does Piauhy collect your Personal Data.
- Who: who are the authorized parties that Piauhy may disclose your Personal Data to.
- Where: where Piauhy and its authorized parties may process your Personal Data.
- How secure: what Piauhy does to protect your Personal Data.
- How Long: Piauhy’s approach to defining the term of retention of your Personal Data.
- Your rights: what your rights are and how you can exercise them.
- How to contact us: where and how you can reach us if you wish to exercise your rights or if you have a question.
What processing activities does this Policy cover?
Specific privacy and data protection information notices (“Privacy Notice”) and/or consent forms will, if necessary, be communicated to you regarding specific situations where Piauhy may process your Personal Data. These Privacy Notices shall describe in more detail how your Personal Data will be processed in relation with the processing in question. If the legislation of your country so requires, this Policy and/or Privacy Notices may be supplemented by local mandatory provisions, as the case may be.
Validity and update of this Policy
Information we collect from you: Information about you or that you provide to us
Piauhy collects, or you may provide to us, several types of information from and about users of our Site, including information:
- by which you may be personally identified, such as name, postal address, e-mail address, telephone number, and other identifying information;
- that is about you but individually does not directly identify you, such as date of birth; and
- about your internet connection, the equipment you use to access our Site and usage details, such as Internet Protocol (IP) address.
We collect this information:
- directly from you when you provide it to us;
- automatically as you navigate through the site; and
- from third parties, for example, our business partners.
a) What are cookies?
This Site uses so-called “cookies”. Cookies are small text files that are stored in the memory of your computer via your browser. They store certain information (e.g. your preferred language or site settings) which your browser may (depending on the lifespan of the cookie) retransmit to us upon your next visit to our Site.
b) What cookies do we use?
We differentiate between two categories of cookies: (1) functional cookies, without which the functionality of our Site would be reduced, and (2) optional cookies used for e.g. website analysis and marketing purposes. The following tables contain a detailed description of the optional cookies we use:
[___The option that always appears when you enter to a site___]
c) Subject to your consent
We only use optional cookies if we have obtained your prior consent (Art. 6(1)(a) General Data Protection Regulation). Upon your first access to our Site, a banner will appear, asking you to give us your consent to the setting of optional cookies. If your consent is given, we will place a cookie on your computer and the banner will not appear again as long as the cookie is active. After expiration of the cookie’s lifespan, or if you actively delete the cookie, the banner will reappear upon your next visit to our Website and again ask for your consent.
d) How to prevent the setting of cookies
The purposes: Piauhy will always collect your Personal Data for explicit and legitimate purposes.
Piauhy collects your Personal Data for the following purposes:
- to carry out our business operations; carry out marketing and sales; respond to your requests; to keep track of our interactions and meetings, such as when you contact us for information and support;
- to comply with legal or regulatory obligations that apply to Piauhy; monitor safety; manage adverse events; carry out prevention and investigatory activities; carry out administrative formalities, registration, declarations or audits.
- to provide patient support, healthcare support services, patient engagement and prescription information; manage claims, including insurance claims;
- to conduct research and development; carry out clinical studies, registries and trials; manage and validate the recruitment and participation of individuals to studies, trials and other operations; analyze demographic data; offer special programs, activities, trials, events or promotions via our services; carry out market or consumer studies;
- to provide you access to online services, application and platforms; manage your online accounts;
- to allow us to identify or authenticate you; provide or verify your credentials including via passwords, password hints, security information and questions, government-issued ID, healthcare professional number, driver’s license data, and passport data.
- to improve and develop our products and services; identify usage trends and develop new products and services; understand how you and your device interacts with our services; track and respond to safety concerns; determine the effectiveness of our promotional campaigns, conduct surveys;
- to personalize your experience when using our services; ensure that our services are presented in the way that best suits you; understand your professional and personal interests in our content, products and services or other content and adapt our content to your needs and preferences; present you products and personalized offers to you;
- to allow us to communicate with you; respond to your requests or inquiries; provide support for products and services; provide you with important information, administrative information, required notices, and promotional materials; send you news and information about our products, our services, our brands, our operations; organize and manage professional events and congresses, including your participation to such events;
- to process payments we may need to issue in a specific situation; verify your financial data; facilitate further payments.
- to offer donations and sponsorships;
- to respond to legal requests from administrative or judicial authorities, in accordance with applicable laws; comply with a subpoena, required registration, or legal process;
- to protect our rights and interests; protect the health, safety, and security of Piauhy personnel and premises; carry out internal audits, asset management, system and other business controls; manage business administration (finance and accounting, fraud monitoring and prevention); maintain the security of our services and operations; protect our rights, privacy, safety or property, to allow us to pursue available remedies or limit the damages that we may incur as necessary; to protect ourselves against possible fraudulent actions.
Why? Piauhy will always process your Personal Data lawfully
Depending on which data we are processing, Piauhy will generally process it on either one of the following legal basis:
- your prior consent: where you have clearly expressed your approval of Piauhy’s processing of your Personal Data. In practice, this will generally mean that Piauhy will ask you to sign a document, or to fill-in an online “opt-in” form or to follow any relevant procedure to allow you to be fully informed and then either clearly accept or refuse the data processing envisaged.
- a contractual relationship between you and Piauhy: in such case, the processing of your Personal Data is generally necessary to the execution or the performance of the contract; this means that if you do not wish Piauhy to process your Personal Data in that context, Piauhy may or will be obliged to refuse to enter into such contract with you or will not be able to provide the products or services covered in that contract.
- legal obligations applicable to Piauhy’s activities; for instance, Piauhy is required to implement pharmacovigilance procedures to monitor adverse effects of marketed products, which generally involves the collection and retention of Personal Data.
- the “legitimate interest” of Piauhy in the sense of applicable data protection law. In such a case, Piauhy shall consider your fundamental rights and interests in determining whether the processing is legitimate and lawful.
Piauhy may, on a case-by-case basis, rely on other legal grounds, such as the protection of your vital interests, in accordance with applicable data protection law, as set forth in the applicable Privacy Notice.
Where does the Personal Data come from? Piauhy will always collect Personal Data from trusted sources.
Piauhy may collect your Personal Data from different sources:
- Data that you communicate to us through various media, through registrations, applications surveys or direct and indirect interactions with Piauhy. For example, data you provide to register to scientific events sponsored by Piauhy, to submit an online application, to send us a request for information, etc.
- Data that we collect automatically, for instance when following your interactions with our websites, platforms, applications and services through certain technologies, such as cookies.
- Data that we collect in accordance with applicable law from public sources available, including data that is published by you in all supports.
- Data that we obtain legally from third parties, for example, when we may need to confirm contact or financial information or to verify licensure of healthcare professionals. In such case, we generally receive such Personal Data from third-parties that are authorized to do so in the framework of their own privacy and data protection policies or in accordance with the law. As applicable, we will inform you in the Privacy Notice of the identity of those third-parties and will invite you to refer to their privacy and data protection policies to inquire on the origin of such Personal Data and the condition of their collection.
About children Personal Data
Piauhy respects the privacy of children, and we are committed to complying with applicable legislation, including the US Children”s Online Privacy Protection Act (COPPA) and the EU General Data Protection Act (GDPR). Our Site is not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18 through our Site. If you are under 18, do not use or provide any information on this Site.
While in some instances we may collect Personal Data about children with the consent of his/her parents or guardian for the provision of our services such as clinical activities or for patient support programs, we do not otherwise knowingly solicit Personal Data from, or market to, children. If a parent or guardian becomes aware that his or her child has provided us with personal information, he or she should contact us as described in the “How to Contact Us” section below. We will take steps to delete such information from our database in accordance with applicable legal requirements.
Who has access to Personal Data: Piauhy will share your Personal Data only with authorized parties.
For the purposes described above, Piauhy may need to share your Personal Data with the following authorized third-parties:
- Piauhy and its affiliates.
- our partners (healthcare professionals and organizations, distributors, other members of the healthcare and pharmaceutical industry).
- selected service providers, vendors or suppliers acting upon our instructions for website hosting, email delivery, data analysis, order fulfillment, auditing, information technology and related infrastructure provision, payment processing, customer service, etc.
- legal or administrative authorities or other parties, when required by applicable laws, including laws outside your country of residence.
- potential acquirers and other stakeholders in the event of a merger, legal restructuring operation such as, acquisition, joint venture, assignment, spin-off or divestitures.
- Sponsors of sweepstakes, contests and similar promotions.
Piauhy may need to share your Personal Data with other third-parties, in which case you will be duly informed through the applicable Privacy Notice.
In any case, Piauhy will require that such third-parties:
- implement appropriate technical and organizational security measures designed to protect the integrity and confidentiality of your Personal Data.
Where Personal Data may be transferred: Piauhy will ensure that transfers of your Personal Data outside EU are safeguarded.
Piauhy is a multinational organization with affiliates, partners and subcontractors located in many countries around the world. For that reason, Piauhy may need to transfer (via access, visualization, storage..) your Personal Data in other jurisdictions, including from the European Economic Area to outside the European Economic Area, in countries which may not be regarded as providing the same level of protection as the jurisdiction you are based in.
Safeguards for international transfers of Personal Data: In cases where Piauhy needs to transfer Personal Data outside the European Union, it shall take appropriate steps to ensure that such recipients of your information are bound to duties of confidentiality, and ensure that adequate safeguards, as required under applicable data protection legislation, will be implemented (including, notably, the European Commission’s Standard Contractual Clauses, as applicable).
In this respect and in particular, for intra-group transfers of Personal Data implemented for clinical studies and pharmacovigilance purposes, Piauhy has implemented and shall apply its “Binding Corporate Rules” validated by the EU Data Protection Authorities.
How secure: Piauhy will implement security measures to protect your Personal Data.
We have implemented a variety of technological and organizational procedures and measures to ensure the integrity and confidentiality of your Personal Data from unauthorized access, use and disclosure. These measures shall take into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.
For instance, we store your Personal Data on servers that have various types of technical and physical access controls, which may include, for instance, if appropriate, encryption. We may also aggregate, pseudonymize or anonymize Personal Data to ensure that no personally identifiable information is communicated to third parties.
However, no data transmission over the Internet or stored on a server can be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information. In the event that we believe that the security of your information may have been compromised, we will endeavor to give you appropriate notice as quickly as possible, including by email, and in accordance with applicable laws.
How long: we will retain your Personal Data only for the necessary time and required by law.
As an exception, Piauhy may be required to retain your Personal Data for longer periods as required or permitted by law, or as necessary to protect its rights and interests. In such a case, you will be informed of the intended retention period in the applicable Privacy Notice.
Your rights: Piauhy will ensure that you can exercise your rights pertaining to your Personal Data.
You can exercise your rights as provided by data protection laws.
To that end, Piauhy informs you that you may, where required by applicable law and subject to limitations which may apply in consideration of exceptions or legal requirements, be entitled:
- Right to Access: to have access upon simple request to your Personal Data – in which case you may receive a copy of such data (if requested), unless such data is made directly available to you, for instance within your personal account;
- Right to Rectification: to obtain a rectification of your Personal Data when such is inaccurate, incomplete or obsolete;
- Right to Deletion: to obtain the deletion of your Personal Data in the situations set forth by applicable data protection law (‘right to be forgotten’);
- Right to Withdraw: to withdraw your consent to the data processing without affecting the lawfulness of processing, where your Personal Data has been collected and processed on the basis of your consent;
- Right to Object: to object to the processing of your Personal Data, where your Personal Data has been collected and processed on the basis of legitimate interests of Piauhy, in which case you will need to justify your request by explaining to us your particular situation;
- Right of Limitation: to request a limitation of the data processing in the situations set forth by applicable law;
- to receive your Personal Data for transmission from Piauhy to a third-party or to have your Personal Data directly transferred by Piauhy to the third-party of your choice, where technically feasible (data portability right allowed only where the processing is based on your consent).
If you would like to exercise any of these rights, please contact us as described in the “How to Contact Us” section below and we will take necessary steps to respond as soon as possible.
You may also file a complaint before a competent data protection authority regarding the processing of your Personal Data. While we suggest that you contact us beforehand, if you wish to exercise this right, you should contact directly the competent data protection authority.
How to contact us
Piauhy Labs Portugal LDA
Praça da Alegria, 50
1250-004 Lisboa, Portugal