La protection des données personelles
WHO ARE WE
We are Ewopharma AG, headquarters of the Ewopharma Group. Our address is Vordergasse 43, 8200 Schaffhausen, Switzerland.
Our contact details are info@ewopharma.com. Phone: +41 52 633 09 99. Our Group Data Protection Officer’s details are Julienne Jameson; j.jameson@ewopharma.com.
PERSONAL DATA PROVIDED TO OR COLLECTED BY EWOPHARMA
The following is a non-exhaustive list of the main purposes in summary form for which your personal data may be processed depending on which category of data subject you fall within.
Please note that access to personal data is managed and controlled within the Ewopharma Group. Your personal data will only be accessed by employees of the Ewopharma Group who have a relevant purpose for accessing your data, e.g. pharmacovigilance personal data may be transferred to our Slovakian affiliate who is the marketing authorisation holder for our own products. It may also be accessed by those who we hire to help us run our business or who we are required to provide information to in line with the law or self-preservation (e.g. fraud). More specific information on the purpose, legal basis, retention/storage period, disclosures, your data protection rights and who to contact in respect of processing and your rights will be provided in specific processing notices which will be available at the time your data is collected or will be notified to you by the relevant employee before it processes your data.
Retention periods vary and Ewopharma shall assess cases according to the processing itself and the risks to you as the Data Subject. There are some general guidelines set out below. For all other situations, your personal data shall be held only for as long as necessary in line with applicable law, to resolve disputes, or strict criteria developed in within the Group Data Protection Program. For specific information, please contact info@ewopharma.com or j.jameson@ewopharma.com.
Type of Processing & Purpose | Personal Data Type | Lawful Basis | Retention Period |
Contract with Ewopharma | Address, name, payment information for example | Contractual necessity. | Duration of contract or as long as specified in the contract |
Current/previous/future customer | Name, business address, telephone number | Legitimate interest | 3 years usually |
Where you receive a payment for services / product / sponsorship, Ewopharma shall retain such personal data in line with any applicable transparency legislation, taxation legislation (or equivalent), and internal retention policy | Payroll/ payment information, name, address | Contractual necessity / legal obligation. | As stated in the contract or local legislation. |
Customer research/ competitions/ surveys | Name, address, personal data specific to the project in question | Usually consent but where special category data is collected, a condition shall also form the legal basis. This shall be communicated to you, in writing, in advance of any participation. | Until completion of the project unless otherwise agreed |
Health data where you use our products or suffer with an ailment/disease in a therapeutic area of our interest. This could be reported to us an adverse event. | Name, address, health data, specific reaction to the product. | Legal obligation and condition 9(h) or (i). | 10 years post withdrawal of marketing authorisation from the market. |
General queries to our email or office which require a reply from us. | Name, email address, telephone number, detail of the conversation | Legitimate interest. | 2 years |
Job applicant | Name, email address, CV, cover letter | Consent or legitimate interest. | 1 year unless specialised job post. |
Transfer of personal data within the Ewopharma Group required in the general course of business | Business details or relevant details depending on the nature of the query | Legitimate interests or consent | Depending on the nature of the query but usually one year unless other time is required |
External accountants | Business details, some HR details such as tax numbers | Legitimate interest, legal obligation and consent | In line with employment/commercial contract, consent or applicable law. |
Third party IT administrators | Access to all data on the server | Legitimate interests | As long as it remains on the server |
Occupational Healthcare professionals | Health data |
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Insurance organisations | Employee data, legal case personal data | Legitimate interests | As required by insurance company, local law and legal cases. |
Marketing through mediums such as email, newsletters, websites, promotional material. | Email address, name, telephone number, home address. | Consent | As set out in the consent form. |
We might also collect your personal data from a third party. The third party should have complied with data protection laws. Where you feel it has not, please contact us.
INTERNATIONAL TRANSFERS
There are several instances where Ewopharma will be required to transfer your personal data outside of the EEA. Where this is required, an employee within the Ewopharma Groupshall only transfer such personal data to a country that has an adequacy decision awarded by the European Commission. This means that you, as a Data Subject, shall be afforded a similar standard of privacy rights in that recipient country as you would within the EEA. Where no adequacy decision is in place, the model clauses that have been authorised by the European Commission or such other protections as are authorised by the European Commission or its delegate, at the time, shall be used. Otherwise, your personal data shall not be transferred.
WHAT WE SHARE
Ewopharma shall not disclose your personal data unless it has a lawful basis for doing so. Where Ewopharma intends to disclose your personal data, it will inform you at the time of collection through this Privacy Notice, your consent, contract or other documentation provided to you. Any personal data shared with our headquarters in Switzerland has been is the subject of an adequacy decision currently and therefore any personal data transferred to our head office shall be adequately protected through appropriate safeguards.
For all other situations, your personal data shall be held only for as long as necessary in line with applicable law, to resolve disputes, or strict criteria developed in within the Group Data Protection Program. For specific information, please contact info@ewopharma.com or j.jameson@ewopharma.com.
YOUR RIGHTS
You have the right to request a copy of any of your personal data and confirm its accuracy or request it be corrected.
You have the right to request that your personal data be erased from our system. Where your personal data is held on the basis of consent, you can withdraw your consent by emailing the contact person on your consent form.
You have a right to, request a restriction of processing or outright object to the processing in certain instances. This will be assessed on a case by case basis.
CONSEQUENCES OF NOT PROVIDING PERSONAL DATA
Ewopharma shall not request any personal data from you that is not absolutely necessary in its opinion. Therefore, if you refuse, we may not be able to interact with you. This will be dealt with on a case-by-case basis.
VISITORS TO OUR WEBSITE
When someone visits www.ewopharma.com we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. Aside from the approximate location (IP address), the information collected by Google Analytics is mostly anonymous traffic data such as browser information, device information and language. We do not collect additional information, such as your age, gender, interests or bank details. The collected information is used to provide an overview of how people are accessing and using our website in order to improve our service and user experience. It is not used for any additional purpose, such as to profile those who access our website.
If you contact us through our website, we will only use this information with the intention of answering the questions/complaints or suggestions sent by you. After the conclusion of your query, your personal data will be destroyed.
SECURITY
We take reasonable steps to protect your Personal Data using physical and/or electronic security measures appropriate to the sensitivity of the personal data.
Although we have enacted security measures, we cannot guarantee the security of any information that you submit via email or over the Internet. Submission of Personal Data using such networks is done at your own risk, since no Internet transmission is ever 100% secure or error-free. You should take special care in deciding what information you send to us via email or posting on our web sites.
THIRD PARTY WEBSITES
You can choose to access certain third party websites and services through our website. Ewopharma is not responsible for the privacy policies or practices of other websites. You should examine their websites for further information on their privacy policy.
We have a Facebook page relating to some our Products. When you choose to share information with Facebook the information you share will be governed by their privacy policies. The social media site may also share information with us and may post information about your visit to our websites on their pages. You can modify your privacy settings with Facebook.
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RIGHT OF COMPLAINT
If you feel your rights have not been fairly or adequately dealt with, you have the right to complain to the data protection supervisory authority.