1.1 Below is described how Italfarmaco Nordics: org. no. 556534–0287, with the address The Park Forskaren, Hagaesplanaden 1, 113 68 Stockholm, ("Italfarmaco", "ITF", "us" or "we"), processes personal data in relation to you.
1.2 Data protection is a priority for us. It is therefore important for us to protect your personal data and ensure that our processing of them is done correctly and lawfully.
1.3 In this privacy policy, we explain the types of personal data we may process and the purposes for which we process them. We also explain our processing of personal data and what choices and rights you have in relation to it. We ask you to carefully read our privacy policy and familiarize yourself with its content. The privacy policy is available on our website.
1.4 Please note that this privacy policy concerns the processing of personal data for which Italfarmaco Nordics is the data controller. This means that we are responsible for the handling and processing of your personal data. It also means that you should contact us with any questions or comments, or if you want to exercise any of the rights you have in relation to our handling of your personal data.
1.5 We may collect personal data about you from various sources, including directly from you personally, but also from documents or forms that you provide to us to participate in Italfarmaco-sponsored activities or other initiatives such as training and development activities. We may also collect other personal data about you, such as CVs and resumes, or from public sources such as databases and websites.
2.1 Personal data refers to data that can be related to you. We may process the following personal data that can be related to you as a contact person for any of our suppliers, healthcare providers, organizations, or other parties we collaborate with, or as a participant in a sponsorship activity organized by us or our partners:
(a) name
(b) email address
(c) telephone number
(d) information about your employer or organization
(e) your title
2.2 If you are a physician or representative of a healthcare provider or organization and act as a contractor or consultant to us, or otherwise have a professional relationship with us, we may process the following personal data that can be related to you:
(a) name
(b) personal identification number
(c) email address
(d) telephone number
(e) information about your employer or organization
(f) your title
(g) information on value transfers
(h) information about your professional life such as practice location, your title, and the medical field in which you operate
(i) information about your professional qualifications and scientific activities such as previously conducted clinical trials, participation in past or ongoing research studies, with Italfarmaco or other companies
(j) academic and scientific publications and articles
(l) membership in associations and boards
(m) financial information such as compensation-related information including personal identification number or other identification number for tax and fee management
(n) information about your contacts with Italfarmaco regarding meetings you have had with us, topics discussed, your knowledge and questions about Italfarmaco's operations and products, what material or products we have shown you, and your feedback, as well as your views and practices regarding prescription, patients, and diagnosis, and similar information.
2.3 We may process the following personal data that can be related to you as a contact through our website, italfarmaco.se.
(a) name
(b) address
(c) email address
(d) telephone number
(e) information you provide in your contacts with us
2.4 In addition, we may process the following personal data that can be related to you as a job applicant at Italfarmaco Nordics:
(a) identity and contact information such as name, date of birth, personal identification number, driver's license number, postal address, telephone number, email address, etc.;
(b) employment history and information about previous employment, education, and other experiences and merits, such as job duties, grades, certificates, and opinions;
(c) credit information;
(d) information on social media.
3.1 Regarding you as a contact person for any of our suppliers or partners, and you acting as a contractor or consultant to us, we process your personal data for the purpose of administering our contracts such as service contracts, sponsorship contracts, and cooperation agreements. The processing is carried out, insofar as it concerns other data than information about value transfers, based on our legitimate interest in being able to contact you within the framework of the agreement and for other administration related to this.
3.2 Regarding you as a participant in a sponsorship activity organized by us or a partner, we process your personal data for the purpose of being able to contact you for marketing purposes. The processing is based on our legitimate interest in being able to market ourselves to you and to evaluate our sponsorship agreements.
3.3 Regarding you as a physician, or person otherwise working in healthcare, we process your personal data for the purpose of administering our relationship with you, including planning potential collaborations, contacts, ensuring that we provide you with information relevant to your medical expertise, interests, and preferences. The processing is based on our legitimate interest in maintaining a professional relationship with you. If we ask you to provide us with personal data to comply with legal requirements or to fulfill an agreement with you, we will inform you of this at the time we collect your personal data and inform you whether the provision of personal data is mandatory or not.
3.4 Regarding you as a contractor or consultant to us, we, in addition to what is described above, also process information about value transfers for open reporting according to the ethical regulations of the pharmaceutical industry in the various Nordic countries. Reporting at an individual level is done with your consent, which you would have given in the service contract you signed with us. If you have not given your consent, Italfarmaco will process your personal data based on its legitimate interest in fulfilling its obligations under the ethical regulations of the pharmaceutical industry and publish value transfers that Italfarmaco will make and has made to you on an aggregated level instead.
3.5 Personal data that can be related to you as contacting us via our websites or telephone are processed for the purpose of handling your case, providing feedback to you, reaching out with marketing of our products, and providing material or samples that you have ordered. Your email address is processed to handle questions you ask on our websites, and your question may be published on the relevant website in anonymized form. Processing under this point is based on your consent.
3.6 Regarding you as a job seeker at Italfarmaco, your personal data are processed for the purposes of managing the recruitment process, conducting background checks, and performing recruitment tests, to evaluate your suitability for employment with us, for example by obtaining information from authorities, courts, and internet searches, and for conducting reference checks. The processing is based on our legitimate interest in recruiting and being able to evaluate the applications received by us. Data in credit information regarding you may be obtained and processed based on your consent.
3.7 In cases where the processing is based on Italfarmaco's legitimate interest, Italfarmaco has reached the conclusion after determining that the processing is necessary for the specific purpose as described above, and after weighing Italfarmaco's interest against your interest in data protection - especially considering the opportunities you have to influence the processing of your data as per point 9. Please contact us if you would like more information about the balancing of interests regarding any individual processing.
3.8 Personal data will not be processed for purposes other than those stated above without first informing you and/or obtaining appropriate consent from you.
4.1 We store your personal data for as long as necessary to fulfill the purpose of the processing, and as a starting point no longer than the period for the current agreement.
4.2 If we process your personal data because you are employed by any of our suppliers or partners, or by an organization that is a contractor in relation to us, and we are informed that your role in relation to us ceases, we will only retain your personal data to the extent and time required to administer the agreement with your employer.
4.3 Data about you as a participant in sponsorship activities organized by any of our partners will be kept for direct marketing until you object to such direct marketing.
4.4 Data about you as a physician or person otherwise working in healthcare and having a professional relationship with us will be kept as long as we have a legitimate business need to keep the data (for example, to provide you with services you have requested or to comply with applicable legal, tax, or accounting requirements). When we no longer have an ongoing legitimate business need to process your personal data, this data will be deleted within 1 year.
4.5 Data about you as a physician or representative of a healthcare provider or organization and acting as a contractor or consultant to us will be kept as long as the data is needed to fulfill our obligations to openly report value transfers according to the ethical rules of the pharmaceutical industry.
4.6 We store personal data that can be related to you as contacting us via our websites or telephone as long as we have your consent to process this personal data. However, data related to you contacting us via our websites or via telephone will be stored for a maximum of one year from the last contact.
4.7 We store personal data that can be related to you as a job seeker with us for as long as the recruitment process lasts. Thereafter, necessary data will be retained for up to 10 years, as long as you or a third party, such as a trade union, can take legal action against us in connection with your application for employment. If you give your consent, your personal data may be stored for 2 years for the purpose of contacting you for future job opportunities.
4.8 To the extent that your personal data are no longer necessary for the purposes of the processing, or for any other reason the processing is no longer permitted, the data will be anonymized or deleted. However, we will always keep your data for as long as required by law.
6.1 We will never sell your personal data to any third party. Italfarmaco Nordics may, however, share your personal data with the following categories of recipients:
(a) with other companies within the Italfarmaco group.
(b) with an authority, court, or other third party where we consider disclosure necessary according to applicable law or regulation, to assert, establish, or defend legal claims, or to protect your or another person's fundamental interests;
(c) with a potential buyer (and its representatives and advisors) in connection with a proposed purchase, merger, or acquisition, provided that we inform the buyer that they may only process your personal data in accordance with this privacy policy; and
(d) with another party with your consent to such sharing, or when required as a result of you exercising any of your rights under point 9.
6.2 Sharing of personal data within the Italfarmaco group is done for the purpose of streamlining and centralizing Italfarmaco Nordics operations. The processing is based on our legitimate interest in streamlining administration and management within the group, as well as streamlining operations.
6.3 We may also disclose your personal data to our data processors, such as companies working with invoice or other financial administration, or IT and cloud services. In such cases, data processing agreements are entered into to ensure that your personal data are processed in accordance with this privacy policy.
7.1 Italfarmaco Nordics ensures a high level of security with regard to the processing of personal data through a range of technical and organizational measures aimed at preventing unauthorized access, use, or sharing, or accidental loss of data. For example, encryption, anonymization, and/or pseudonymization are used where appropriate. Personal data is securely stored in systems dedicated to that purpose. Our internal procedures are established to prioritize and promote the protection of personal data.
7.2 Although our data protection measures are continuously evaluated and updated, it is difficult to guarantee the security of data shared over the internet. Therefore, you are requested to exercise caution and protect yourself when sharing data online, especially when using passwords, by using appropriate firewalls and programs that protect against spyware and other viruses.
7.3 If, against all odds, you discover deficiencies in Italfarmaco Nordics' data protection, especially regarding security incidents such as an email sent to the wrong recipient or otherwise gone astray, or documents related to Italfarmaco left in an insecure location, we ask you to contact us immediately.
8.1 You have the right to receive confirmation from us as to whether we are processing personal data concerning you, and if so, access to this personal data and also information about the personal data and our processing of it.
8.2 You have the right to have incorrect personal data concerning you rectified by us without undue delay. Taking into account the purposes of the processing, you also have the right in certain cases to have incomplete personal data completed.
8.3 You have the right, under certain circumstances, to have your personal data erased by us, for example if the personal data is no longer necessary for the purposes for which it was collected, or if the personal data has been processed unlawfully.
8.4 You have the right to demand that we restrict the processing of your personal data in certain cases. For example, if you dispute the accuracy of the personal data, you may request that we restrict the processing of it while we verify its accuracy.
8.5 You have the right to object to the processing of your personal data carried out on the basis of Italfarmaco's legitimate interest. If this happens, we must demonstrate compelling legitimate grounds that override your interests, rights, and freedoms in order to continue the processing.
8.6 You have the right to object to the processing of your personal data to the extent that the processing is carried out for direct marketing. Upon such objection, we will no longer process your personal data for that purpose.
8.7 You have the right, under certain circumstances, to receive the personal data that you have provided to us and that concerns you in an electronic format that is commonly used. You have the right to transmit such data to another data controller (data portability).
8.8 If you have any comments on how we process your personal data, you are welcome to contact us at the email address provided below. You also have the right to lodge a complaint with the Swedish Data Protection Authority.
We may make additions or changes to this privacy policy. If we do so, we will publish the updated policy on our website. If this happens, we ask you to carefully read through the updated privacy policy.
Italfarmaco Nordics
The Park Forskaren
Hagaplan 4
113 68, Stockholm, SWEDEN
Copyright © Italfarmaco Nordics. All rights reserved.
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