Last update: July 2018

Almirall, S.A. (“Almirall“, “we“, “us“, “our“) is committed to the safeguard of the privacy of its stakeholders and the compliance of the data protection principles and applicable laws.

This Privacy Policy (together with our Terms of Use, Our Cookies Policy and any other documents referred to in it) 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.

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

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. What kind of personal data we process?

We may collect and process the following data about you:

1. Information you give us. You may give us information during your registration process in the Site or whenever you fill in a form which is necessary in addition to such register, whenever you edit your personal profile and/or when you report a problem with our Site.

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, address, e-mail address, country, specialty, work centre and phone number.

2. Information we collect about you. As you navigate around the Site, certain information can be passively collected (that is, gathered without you 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

3. Information we receive from other sources. We may receive information about you if you use any of the other websites we operate through the use of Cookies or other services we provide or from other interactions with you. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this Site and from other sources. We are also working with third parties (including, for example, business partners, sub-contractors in technical and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them just if you give us your consent.

Information gathered through cookies will be processed in aggregate unless you give us specific consent to link it to your profile by accepting to receive customized interaction with you as more fully explained in section 3.2) below.

Except where expressly stated, the provision of your personal data is voluntary and does not affect the quality or use of the services offered by Almirall. However, missing or incorrect mandatory personal data may make it impossible for Almirall to provide the services you have requested.

3. For what purposes do we need your personal data?

Your personal data will be used for different purposes as follows:

1. To provide you with the services and contents to which you may have access through almirallMed platform, such as for instance, events, publications, training, webs & apps, products, education to patients, media. Some of these services will require prior registration and some others will be open and can be used without the need that you register in almirallMed. These Platform Services also include sending electronic communications strictly related to almirallMed as more fully explained in our Terms of Use. Part of the data is collected also in order to ensure error-free provision of the Site, improve the services offered through the platform and to offer you customized views depending on the data that you have already provided during the registration process. We could also use them to obtain an analysis about the traffic of our Site with the aim of improving the offered contents and providing a better service.

2. Improve your user experience and have a customized interaction with you by combining data of your activity, interests and preferences, your navigation habits and behaviours, collected in the platform or gathered from internal and external sources. Please see our Cookies Policy for more information, especially the section related to the tracking tools.

3. To provide you with communications or news about Almirall activities, products and services, through any channel (e-mail, post mail, telephone, and others). This information may include those of Almirall affiliates belonging to the same group of companies. You can find more information about our affiliates at www.almirall.com. Such communications, which might be commercial communications, will or might be customised and addressed to you in attention to the information you have voluntarily provided to us through the registration process or from internal sources. If you give us your consent to the purposes indicated in section 3.2) above, we might combine such information with your navigation habits and behaviours, collected in the platform or gathered from internal and external sources.

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

4. How long will we keep your personal data?

The personal data you provide to us will be stored and processed until the earlier of: your request to us to erase your personal data and cancel your account (as indicated in section 6 below), or until the period of time in which Almirall is obliged to comply with any legal obligation that may arise in connection with any service provided through almirallMed or if we identify you as an “inactive” user, as more fully detailed in our Terms of Use .

5. What is our lawfulness to process your personal data?

The processing of your personal data for the purposes indicated above is based on your specific consent. If you use the Site without register and log in, the lawfulness lies on the legitimate interest we have to run the Site and the performance of a contract or pre-contractual measures.

6. Who do we share your personal data?

Data will not be shared with third parties other than our services providers who help us to better provide you with the services related to almirallMed and to make direct marketing based on your profile (i.e. agencies that help us to organise events, for digital campaigns, data analytics, amongst others), (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, the relevant Privacy Shield certification or binding corporate rules of the data processor.

7. What are your rights as data subject 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:

1. Right of access: means the right to obtain access to your information that Almirall processes.
2. Right to rectification: means the right to be entitled to have your information corrected if it is inaccurate or incomplete.
3. Right to erasure: in simple terms, it means to request the deletion or removal of the information concerning him/her 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.
4. 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.
5. 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.
6. 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.

If you would like to exercise any of the abovementioned rights, you can send us an electronic request to our address contacto@almirallmed.es,  attaching a copy of your personal ID card/passport.

Finally, we inform you that you can contact the Spanish Data Protection Agency or any European supervisory entity for any claim arising from the processing of your personal data. You can find an updated list of these organizations by jurisdiction in https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm