Privacy policy

Last update: February 2022

This Privacy Policy sets out the basis on which any personal data we collect from you when you navigate in this site (the "Site"), or that you provide to us on a voluntary basis, will be collected and processed by us.

By visiting our Site you are agreeing to the practices described in this policy. By providing personal information to us or by using the Site, you agree to the terms and conditions of this Privacy Policy.

For more information about this document or how we process your personal data, you can contact our Global Data Protection Officer at the e-mail address dpo.global@almirall.com

1. Basic information

2. Additional information
 

2.1. WHO IS THE CONTROLLER OF THE DATA YOU PROVIDE?

For the purpose of the General Data Protection Regulations and any local applicable laws, the data controller of the data you provide through this Site is Almirall, S.A., a Spanish company with registered office at Ronda General Mitre 151, 08022 Barcelona, with VAT number A-58869389, registered at the Companies Registry of Barcelona at Volume 21795, Sheet 32, Page no. B-28.089 and with the Ministry for Health and Consumer Affairs Registration Number - 1889E.

You can contact Us at the telephone number (+34) 93 291 30 00.

Please note that data controller means the legal entity that decides the purposes and means of processing your personal data.

2.2. WHICH KIND OF PERSONAL DATA WE PROCESS?

We may collect and process the following data about you:

a) Information you give us. You may give us information through different forms available in the Site, telephone, email or otherwise for different purposes, including the following:

a. To report an adverse event.

b. To ask for medical information on our products.

c. To solve your queries related to media, investors, R&D activities, and partnering with Almirall.

d. To subscribe to e-mail alerts on Almirall's news, financial information, etc. and to get access to some specific information and materials (product-related press releases, webcasts, conferences and other presentations, etc.).

e. To give us feedback on any particular matter.

f. If you are a Supplier or a Partner of Almirall, we may process your personal data to manage our commercial relationship and contracts with you and/or to check whether there is any conflict of interest or to ensure compliance with legal requirements or with our policies.

In each case, we try to limit to collect the necessary information we need for the purposes to process your request in each case. The information you give us may include your name, surname, e-mail address, country, and phone number.

In relation to drug safety, we may contact you to follow up the particular case reported and additional personal data might be collected for such purposes.

b) Information we collect about you. As you navigate around the Site, certain information can be passively collected (that is, gathered without your actively providing the information), using various technologies. We and our third-party service providers passively collect and use information in a variety of ways, including the following:

• Using cookies: Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, and language preferences. We and our service providers use the information for security purposes, to facilitate navigation and to display information more effectively. We also use cookies to recognize your computer or device, which makes your use of the Site easier and makes the Site display properly on your device. In addition, we use cookies to gather statistical information about Site usage in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it. Some of our cookies are managed for us by third parties. You can refuse to accept these cookies by following your browser's instructions; however, if you do not accept them, you may experience some inconvenience in your use of the Site. To learn more about cookies, please take a look to our Cookies Policy.

• Through your browser: The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are: browser type and browser version, operating system used, deferrer URL, host name of the accessing computer, time of the server request and IP address.

These data are not combined with other data sources.

The provision of your personal data is voluntary (except where expressly stated). However, missing or incorrect mandatory personal data may make it impossible for Almirall to provide the information you have requested.

2.3. WHAT USES ARE MADE OF YOUR INFORMATION?

We use your personal data in the following ways:

a) Report an Adverse Event: At Almirall, our commitment to the safety of our medicines, cosmetics and healthcare products starts from the Research and Development (R&D) department and is maintained throughout the life of our products. Therefore, we will use the personal data you provide us through the "Report a side effect" form to identify, quantify, assess and prevent potential risks arising of the use of our medicines, as well as proactively contacting you to obtain further information about any case that you report. When contacted in the first instance you can choose to be contacted again or not, and if not, we will block your contact on the database. All these activities are  in compliance with our legal obligations with the competent Authorities.in the field of pharmacovigilance, materiovigilance and cosmetovigilance. Please check our specific Global Drug Safety Privacy Policy for more details.

b) Medical information: As part of our obligation as pharmaceutical company, we also collect your personal data for the purposes to respond to your queries related to our products and medicines.

c) Solve your queries or receive your feedback in relation to other matters: we also collect your data for the purposes to solve your enquiries in relation to media, R&D activities, and partnering with Almirall, or simply to receive your feedback.

d) Provide you by e-mail alerts with our press releases and financial information upon request. This information is particularly addressed to journalists, financial investors and analysts.

e) Provide you access to specific information (product-related press releases, access to our webcasts, conferences and other presentations, etc.).

f) Relations with our Partners and Suppliers: The personal data we process from our partners or suppliers is generally limited to contact information (name, name of the organization, phone, email and other contact details) and financial information (payment-related information) to manage our commercial and, as the case may be, contractual relationship. In addition, we may also process some data to check whether there is any conflict of interest or to ensure compliance with the applicable legal requirements or with our policies.

g) Site maintenance: Part of the data is collected in order to ensure error-free provision of the Site and improve the services offered through the Site.

Your personal data will not be used for any other different purposes.

2.4. FOR HOW LONG WILL WE KEEP YOUR PERSONAL DATA?

The personal data you provide to us will be stored and processed as follows:

a) Drug safety: Personal data provided will be kept in accordance to our Global Drug Safety Privacy Policy for more detail.

b) Medical information: the personal data provided will be kept for the time necessary to solve your query.

c) Solve your queries or receive your feedback in relation to other matters: the personal data provided are not stored and it is only used to solve your query.

d) E-mail alerts: the personal data provided will be kept until you decide to unsubscribe from this service.

e) Access to specific materials and information: the personal data provided will be kept until you notify us that you want to cancel your access.

f) Relations with Partners or Suppliers: We will only retain Suppliers’ personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal or regulatory requirements. When this period expires, your personal data will be removed from our active systems.

g) The data retention period of the personal data you provide to us through the use of cookies is explained in our Cookies Policy.

2.5. WHICH IS OUR LAWFULNESS TO PROCESS YOUR PERSONAL DATA?

The processing of your personal data for the purposes indicated in section 2.3 above lies on.

a) Drug safety: compliance with a legal obligation

b) Medical Information: compliance with a regulatory obligation to which Almirall is subject.

c) Other queries: We have your consent when submitting your query or your comments.

d) E-mail alerts: your consent for getting subscribed to our email alerts.

e) Provide you access to specific information: your consent

f) Relations with partners and suppliers: depending on the circumstances, the processing can be based on the execution of a contract to which the data subject is party in case on an individual, or in our legitimate interest of conducting business with our partners and suppliers. Processing may also be necessary for compliance with a legal obligation to which Almirall is subject, as well as our legitimate interest or public interest in safeguarding any conflict of interests or to conduct investigations to avoid bribery or other illegal practices.

g) Site maintenance: Almirall’s legitimate interest to provide you with the site without errors.

In relation to the information we gather through cookies from a technical perspective, we have a legitimate interest to run properly the Site. Other Cookies used for statistical purposes or to acquire an aggregate overview of our visitors shall be subject to consent, without making any predictions or drawing any conclusion about an individual. You can also visit our Cookies Policy for more information.

2.6. ARE WE GOING TO SHARE YOUR PERSONAL DATA?

Except for legal obligation, your data will not be shared with third parties other than our services providers who help us to pursue our regulatory obligations and/or better provide you with the services or information requested (hereinafter, the "Recipients").

Whenever information needs to be transferred to Recipients outside the European Economic Area to a country which has not received the decision of adequate level of protection issued by the European Commission, personal data will be duly protected by standard contractual clauses approved by the European Commission, or binding corporate rules of the data processor as well as any other adequate safeguards and supplementary measures, as necessary.

2.7. WHICH ARE YOUR RIGHTS AS DATA SUBJECTS AND HOW YOU CAN EXERCISE THEM?

You may exercise at any time any of the following rights before Almirall in connection with the processing of your personal data:

a) Right of access: means the right to obtain access to your information that Almirall processes.

b) Right to rectification: means the right to be entitled to have your information corrected if it is inaccurate or incomplete.

c) Right to erasure: in simple terms, it means to request the deletion or removal of the information concerning you where there is no compelling reason for an organisation to keep using it. This right is also known as "the right to be forgotten" and is not a general right to erasure; there are exceptions.

d) Right to restrict processing: means the right to ‘block' or suppress further use of the information concerning You in certain circumstances. When processing is restricted, we inform you that Almirall can still store your information, but may not use it further.

e) Right to data portability: means the right to obtain and reuse personal data by a third party in a structured, commonly used and machine readable format in certain circumstances. If you request the direct transfer of the data to another data controller, this will only take place if it is technically feasible.

f) Right to object: means the right to object to certain types of processing, in certain circumstances.

The lawfulness of the data processing up to your consent withdrawal remains unaffected by the revocation. These rights may be limited in some situations – for example, where we can demonstrate we have a legal requirement to process your personal data.

If you would like to exercise any of the abovementioned rights, you can send us an electronic request to the following contact addresses, attaching a copy of your personal ID card/passport.

You can download a form to do this here.

Finally, we inform you that you can contact your national Supervisory Authority for any claim related with the use of your personal data Our Members | European Data Protection Board (europa.eu)