Privacy Policy

This policy (together with the terms of use set out in the legal notice and any other documents referred to on it) sets out the basis on which the Consortium, as defined in the legal notice (“We”, “Us” “Our”) will collect personal data from you and how they will be processed. We encourage you to read this entire Privacy Policy before using or submitting information to this site (“Site”). By providing personal information to us or by using the Service, you acknowledge that you have read and understand this Privacy Policy.

This site is intended for use by residents of the European Economic Area (“EEA”).

The Parties to the Consortium, as joint controllers of the personal information collected by these means have closed the relevant agreement to regulate their respective responsibilities, in accordance with art. 26 of the GDPR. The agreement in essence establishes the delegation on ApotheCom of all their obligations vis-à-vis the data subjects. In this sense ApotheCom will, among other things, provide sufficient information to the data subject, collect any consent, when applicable and attend the privacy rights claim and manage them in the name of the Consortium. ApotheCom is the entity managing and processing the personal data on behalf of the Consortium, that is, the data processor (“the administrator”).

Information collection

We may ask you to submit personal information in order for you to be able to contact us, so that we may answer your query. You will be informed what information is required and what information is optional.

If you submit any personal information relating to another individual to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Sensitive information

Unless we specifically request or invite it, we ask that you not send us nor disclose, any sensitive personal information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or philosophical beliefs, health or medical condition, sex life or sexual orientation, criminal background, or trade union membership, or biometric or genetic data for the purpose of uniquely identifying an individual) on or through the Service or otherwise directly to us.

Use by Minors

This Site is not directed to individuals under the age of 18, and we request that these individuals not provide personal information through the Site. If your child has submitted Personal Information and you would like to request that such Personal Information be removed, please contact us as explained below under Contacting Us.

Passive information collection (cookies).

Automatic information collection and use

As you navigate around the Site, we and our service providers may automatically collect and use information by means of 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 Service, pages visited, and language preferences. We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Service. We also use cookies to recognize your computer or device, which makes your use of the Service easier. In addition, we use cookies to gather statistical information about Service usage in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it.

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 Service. To learn more about cookies, please visit http://www.allaboutcookies.org.

For further information to this regard please read our Cookie Policy section below.

Use and disclosure of information

Except as otherwise stated, we may use information collected via this Site, to provide the functionality of the Service to you and providing you with related customer service, to respond to your inquiries and fulfil your requests or to send you important information regarding our relationship with you or regarding the Service, changes to our terms, conditions, and policies and/or other administrative information.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

In addition, we may make full use of all information acquired through this Site for data analysis, for example, to improve the efficiency of the Site, for audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements or for fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.

We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

In addition, we may disclose personally identifiable information you provide via this site to third parties but only

• to contractors we use to support our business (e.g., ApotheCom, fulfilment services, technical support, delivery services, and financial institutions), in which case we will require such third parties to agree to treat it in accordance with this Privacy Policy and use it for the same purposes;
• to respond to law enforcement requests or where required by applicable laws, court orders, or government regulations;
• As permitted by applicable law to respond to requests from public and government authorities, which may include authorities outside your country of residence;
• To enforce our terms and conditions;
• To protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.

We may also use and disclose your information in other ways, after obtaining your consent to do so. In addition, where allowed by applicable law, we may use and disclose information that is not in personally identifiable form for any purpose. If we combine information that is not in personally identifiable form with information that is identifiable (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined. Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Service or by providing consent to us (where required by law), your information may be transferred to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country of residence. Nonetheless, appropriate contractual and other measures are in place to protect personal information when it is transferred to our affiliates or third parties in other countries.

How you can access, change, or delete your personal information

If you would like to review, correct, update, restrict, or delete your personal information, or if you would like to request an electronic copy of your personal information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), please contact us via an e- mail to mph@apothecom.com or ApotheCom, FAO MPH, 6th Floor, Holborn Gate, 26 Southampton Buildings, London WC2A 1AN, United Kingdom We will respond to your request as soon as reasonably practicable and no later than one month after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.

Security

This site takes reasonable steps to protect personally identifiable information as you transmit it to our site and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no Internet transmission is ever completely secure or error-free. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.

Retention Period

We will retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

For example, if we collect your personal information to answer to your consult, we will store it until your query has been solved from receipt of the request.

Please note, however, that this is not an exhaustive list of retention periods. Your personal information may be stored for a longer period using the criteria set forth in the first paragraph of this section, especially points (ii) and (iii).

Contact

If you have any questions, comments, or concerns about this Privacy Policy or the information practices of this site, or if you would like to opt out of future communications please contact: ApotheCom, FAO MPH, 6th Floor, Holborn Gate, 26 Southampton Buildings, London WC2A 1AN, United Kingdom or email mph@apothecom.com.

The Consortium, as defined in the legal notice are responsible for collection, use, and disclosure of personal information under this Privacy Policy.

Lodging a Complaint with a regulator

You may lodge a complaint with a supervisory authority competent for your country or region. Please click https://edpb.europa.eu/about-edpb/board/members_en for contact information for such authorities.

Changes to this privacy policy

If this privacy policy changes, the revised policy will be posted on this Site. Your use of the Service following these changes means that you accept the revised Privacy Policy. We recommend that you regularly review the Privacy Policy when you visit the Service. This policy was last updated in January 2021.

Cookie Policy

This Cookie Policy is designed to tell you about our practices regarding the collection of information through cookies and other tracking technologies (like gifs, web beacons, etc.).

The functionalities for which we use these technologies may include the following:

• Assisting you in navigation;
• Analyzing the use of Site;
• Offering content of third parties (such as social media content).

Below is a detailed list of the cookies we use, with a description of its purpose(s), expiry and information on refusing the Cookies in “How to Block”.

Except where allowed by applicable law, we place cookies after having received your consent.

Links to other websites

This site may contain links or references to other websites. Please be aware that we do not control the cookies / tracking technologies of other websites and this Cookie Policy does not apply to those websites.

How to Contact Us

If you have any questions, comments, or concerns about this Cookie Policy or the information practices of this site, please use the contact information included in our Privacy Policy.

Changes to This Cookie Policy

If this Cookie Policy changes, the revised policy will be posted on this site. This Cookie Policy was last updated January 2021

Annex A: Types of Cookies Used on This Website