Registration Policy

Pursuant to Art. 13 of the GDPR, Italfarmaco S.p.A., as Data Controller (hereinafter also referred to as the “Data Controller”) provides you with some information regarding the processing of your personal data provided via the form available on the registration webpage for RESTRICTED AREA of the website www.itfrarediseases.com (hereinafter, “Website”). This information notice is aimed at informing you on how Italfarmaco S.p.A. processes your personal data upon the registration to the RESTRICTED AREA of the website.

This information notice is provided solely for the form available on the registration webpage for RESTRICTED AREA of the website www.itfrarediseases.com (and it does not concern other websites accessible by the user through the links contained within the Website.

A. Categories of personal data and data source

Italfarmaco S.p.A. will collect the following personal data: name, surname, country, e-mail and other relevant information I might be requested with the purposes of validating my identity as a healthcare professional.

Except for pharmacovigilance purposes, the processing of so-called special data as defined by art. 9 of the GDPR (such as data relating to health) and / or data relating to minors is expressly excluded. More information about the processing of personal data for pharmacovigilance purposes is available in www.italfarmaco.com/pharmacovigilance

B. Purpose of the processing and legal basis. Data retention period

The personal data provided voluntarily by the user will be processed for the following purposes:

1) Registration and creation of a personal profile for the access to the RESTRICTED AREA of the website

Your Registration is a necessary step for access to the RESTRICTED AREA of the website, and involves the creation of a personal profile for the management of personal information. In this phase, the Data Controller ask you to enter your name, surname, email, country and a personal password. The personal data provided will be processed to verify your professional qualifications and allow you to register in the reserved area of the website.

The legal basis for the processing of personal data is the execution of pre-contractual measures adopted at the request of the interested party and/or the execution of a contract of which the interested party is a part (art. 6, paragraph (1), letter (b) EU Reg. 2016/679).

Personal data will be kept for the entire duration of the access to RESTRICTED AREA and, subsequently, for the period equal to that of the ordinary prescription.

2) Defence in court

Personal data may be used for defence by the Data Controller in court or in the stages leading to possible legal action against abuse by users of the data or related services. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the web app.

The legal basis that justifies the processing of personal data is constituted by the provisions of art. 9 par. 2 letter f) of EU Reg. 2016/679 (legitimate interest of the Data Controller) in compliance with the conditions of lawfulness pursuant to art. 6 paragraph 1 letter f) of EU Reg. 2016/679.

In the event of a judicial or pre-judicial dispute, the data will be kept for the entire duration of the dispute, until the time limits for appealing the decision have expired.

At the end of the aforementioned retention periods, personal data will be deleted, destroyed or made anonymous, without prejudice to any further processing required by law and the Data Controller’s own backup policies.

3) CRM Management

Your personal data provided will be processed by Italfarmaco S.p.a. to manage, also through our databases and/or information software for so-called Customer Relationship Management (CRM), scientific information interactions.

The consent constitutes the legal basis for the aforementioned data processing, pursuant to Art. 6, paragraph 1 letter a) GDPR.

The personal data will be processed for the above-mentioned purposes until you decide to revoke your consent and/or obtain the termination of the processing. Your personal data will be retained for 10 years from the termination of the processing or from the date of a binding decision issued by a competent authority (e.g. court ruling), whichever is later, for longer periods of time prescribed by law.

4) Receiving informative scientific material

Your personal data will be processed by Italfarmaco S.p.A. to send via e-mail or other electronic systems, informative scientific material (regularly approved by the competent authorities) on products and/or promotional / non promotional activities initiated and organised by the company.
The consent constitutes the legal basis for the aforementioned data processing, pursuant to Art. 6, paragraph 1 letter a) GDPR.

The personal data will be processed for the above-mentioned purposes until you decide to revoke your consent and/or obtain the termination of the processing. Your personal data will be retained for 10 years from the termination of the processing or from the date of a binding decision issued by a competent authority (e.g. court ruling), whichever is later, for longer periods of time prescribed by law.

5) Profiling

The personal data provided will be processed by Italfarmaco S.p.A. to create a professional profile (Profiling). This profile will be developed based on the technical-scientific areas of interest you have shared with us and may factor other assessments carried out by the company. The company may perform these assessments to estimate your interest in its therapeutic areas by combining information about your professional activity with market data.

Your professional profile will be used to:

• Guide the scientific information and product promotional activities carried out by company’s scientific representatives and the company’s authorised personnel;
• Optimising our technical-scientific information service through an interaction that is truly targeted to the doctor’s scientific update needs for greater protection of collective health.

The consent constitutes the legal basis for the aforementioned data processing, pursuant to Art. 6, paragraph 1 letter a) GDPR.

The personal data will be processed for the above-mentioned purposes until you decide to revoke your consent and/or obtain the termination of the processing. Your personal data will be retained for 10 years from the termination of the processing or from the date of a binding decision issued by a competent authority (e.g. court ruling), whichever is later, for longer periods of time prescribed by law.

C. Processing methods and scope of communication of personal data

The processing of personal data will be carried out by authorised personnel using tools that guarantee security and confidentiality and may be carried out with the aid of manual, computerised and telematic tools suitable for storing, managing and transmitting the data (including but not limited to CRM tool implemented by Italfarmaco S.p.A.).

The data will be made accessible only to those who, due to their duties, have been expressly appointed and instructed to process personal data by the Data Controller pursuant to Article 29 of the GDPR.

The data may also be processed by companies that perform technical and organisational tasks on behalf of the owner, including but not limited to: companies that deal with the management and technical maintenance of the site or third parties with whom the Owner collaborates for commercial services. The aforementioned companies have been appointed by the Data Controller as external processors of personal data pursuant to Article 28 of the GDPR.

The updated list of data processors is available, upon request, by sending a communication to the contacts indicated below.

Furthermore, in addition to the aforementioned subjects, the data may be communicated, where required or ordered by current legislation, to the competent supervisory and control authorities, to tax authorities and other authorities, within the scope of their own spheres of competence.

With regard to the possible transfer of data to countries outside the EU, including countries that may not guarantee the same level of protection provided by the applicable GDPR, the Data Controller informs you that the processing will in any case be carried out according to one of the methods permitted by the GDPR, such as for example your consent, the adoption of Standard Clauses approved by the European Commission, the selection of subjects adhering to international programmes for the free circulation of data or operating in Countries considered safe by the European Commission.

The data will not be disseminated.

D. Nature of the provision of data

The provision of personal data is optional. However, failure to provide all or part of the data will make it impossible for Italfarmaco S.p.A. to provide the services for which the data is required.

E. Your rights

Pursuant to articles 15 to 22 of the GDPR, you have the right to obtain from the controller the rectification, integration or erasure (right to be forgotten) of your personal data; the right to obtain the restriction of processing and the right to data portability, the right to object to the processing of personal data, including profiling and, finally, the right to lodge a complaint with the Guarantor Authority. For a complete list please visit: https://gdpr-info.eu/chapter-3/

You may exercise your rights as per articles 15 to 22 of the GDPR and request information at any time regarding the processing of personal data by Italfarmaco S.p.A., and also oppose the processing in cases prescribed by law, by contacting:

Italfarmaco S.p.A.
Via dei Lavoratori, 54
20092 Cinisello Balsamo (Milan, Italy)
infoprivacy.italy@italfarmacogroup.com

In the case of personal data processing for which your consent is required, you have the right to revoke your consent at any time. Such revocation may be exercised through the contact details indicated below.

F. Data controller and Data Protection Officer

The data controller is:

Italfarmaco S.p.A.
Via dei Lavoratori, 54
20092 Cinisello Balsamo (Milan, Italy)

The designated personal data protection officer (DPO) pursuant to art. 37 of the GDPR of Italfarmaco S.p.A. can be contacted for any questions or requests by writing to the e-mail address infoprivacy.italy@italfarmacogroup.com or to the address:

Data Protection Officer c/o Italfarmaco S.p.A.
Via dei Lavoratori, 54
20092 Cinisello Balsamo (Milan, Italy)