Terms of use/Privacy/Cookies

The purpose of this notice is to describe in summary form the processing of by RECORDATI RARE DISEASES, Société à Responsabilité Limitée from Data Subjects as defined below.

This notice is provided pursuant to :

  • art. 13 and 14 of the Regulation (EU) 2016/679 General Data Protection Regulation (hereinafter, “GDPR”), and
  • The UK Data Protection Act 2018 (and regulations made thereunder), the UK GDPR (as defined in section 3(10) (as supplemented by section 205(4)) of the Data Protection Act 2018), the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) and all applicable data protection and privacy legislation in force from time to time in the UK (hereinafter “Data Protection Legislation”)

and is made to those individuals resident in the United Kingdom who interact with the services of Recordati Rare Diseases (hereinafter, “Data Subjects”).

Where required, specific notices on personal data processing activities are provided in order to describe purposes and methods of processing activities for each specific service web page. As per processing activities described therein, the Data Subject can freely give his/her consent.

It is important that Data Subjects read this notice together with any other privacy policy or notice provided by RECORDATI RARE DISEASES when it is collecting or processing personal data about Data Subjects so that Data Subjects are fully aware of how and why RECORDATI RARE DISEASES processing personal data. This notice supplements other notices and policies and is not intended to override them.
 

The “Data Controller”

Recordati Rare Diseases UK Ltd with registered office in Origin, Western Road Bracknell RG12 1US, United Kingdom is the Data Controller for the processing of personal data in the UK.

RECORDATI RARE DISEASES, Société à Responsabilité Limitée located at Immeuble Le Wilson - 70, avenue du Général de Gaulle - 92800 Puteaux, FRANCE shall be the local point of contact and representative in the EU for individuals and data protection authorities.

Without prejudice for the foregoing, the Recordati Group Data Protection Officer, easily reachable by writing to groupDPO@recordati.com, shall be contacted for any privacy issue arising or in connection with the processing of Personal Data.

 

Personal Data assignment

Personal data are collected from the Data Subject through the following methods:

  • Direct submission of data provided by Data Subjects (please refer to the section “Data voluntarily provided by Data Subjects”);
  • Automated collection (please refer to sections “Browsing data” and “Cookies”).

 

Type of data processed

The following categories of data might be collected through the Website and be subject to data processing activities.
 

Browsing data

During the normal course of their activities, the IT systems and software applications provided for the functioning of the Website acquire some personal data (e.g. IP addresses or the domain names of the computers used by Website users, the pages visited and the date and time of the visit) and their transmission is an intrinsic part of the use of internet communication protocols.

This information is not collected with the purpose of being associated with identified persons, but by its nature it could allow the identification of data subjects, following data processing and association with other data held by third parties.

This data is used for the only purpose of acquiring anonymous statistical information on the use of the Website and to monitor its proper functioning. The data could be used to establish responsibility in the case of hypothetical computer crimes that may damage the Recordati website. Apart from this particular circumstance, data on web contacts are normally kept for no longer than 30 days.
 

Cookies

In order to make the browsing on this Website faster and more efficient, cookies are used when users visit this Website. Cookies are short strings of text which allow the connection with the Website to be maintained.

Cookies do not retain any personal information related to the users, and any identifiable data will not be stored. If you want to disable the use of cookies, you must customize the settings in your browser, either by setting it to delete all cookies or by configuring a warning message to appear when cookies are stored.
 

Data voluntarily furnished by Website users

This refers to personal data freely given by a user of  services of Recordati Rare Diseases in order to access specific services that have been freely chosen. This includes contact details and other personal data:

  • provided by Data Subjects to Recordati Rare Diseases in the course of or in connection with conferences and webinars;
  • provided by direct submission by Data Subjects, e.g. by email; and
  • provided through legitimate mailing lists provided by third parties.


Failure to provide this information may result in the service requested being unavailable or restricted. Specific information and consent requests are reported on the pages of the Website used for particular on-request services.
 

Data processing activity purpose

RECORDATI will only use personal data where the law allows. Personal data processed under this notice is processed for the purpose of administration and/or marketing, in each case based on the Data Subject’s consent and/or the legitimate interest of delivering the Services of Recordati Rare Diseases.  

 

Data Communication and disclosure

Save as set out in the following paragraph, personal data will not be disclosed to third parties.

Personal Data may be sent to other companies belonging to the RECORDATI Group or to associated companies of the Group, and to third parties which Recordati uses to improve the service offered through its Website.

The Data Controller will only rely on Data Processors which provide sufficient guarantees to implement appropriate technical and organizational measures, so that the processing activity meets the requirements of the GDPR, and which guarantee the protection of Data Subject’s rights.

The company Webmaster has been appointed as a Data Processor. It processes personal data on behalf of the Data Controller and is responsible for the maintenance of the technological part of the Website.

This Website uses the web analysis service provided by Google Analytics. This is a web traffic analysis service provided by Google Inc (“Google”). Information generated by cookies is transmitted to Google and stored in their servers and IT systems in the USA. Google uses this information to track visitors and examine the use of the Website, to compile reports on the activities of the Website for the site administrators and to provide other services relating to the activities of the Website and the use of the internet. Google can also pass this information on to third parties where this is required by law or where these third parties process the aforementioned information on behalf of Google. Google will not associate your IP address with any other data possessed by Google. By using this Website, you consent to the processing of your navigation data by Google for the above purposes and using the above methods. Please see the Google privacy page for further information. You can prevent Google from acquiring cookies that are generated by visitors to this Website (including your IP address) and from processing that data by downloading and installing this plug-in for your browser http://tools.google.com/dlpage/gaoptout?hl=en

Personal Data may be passed to authorized persons - such as Pharmacovigilance, human resources, medical information departments as well as any appropriate departments of the Data Controller by the Data Controller for processing activities.

 

How data is processed

Personal data processed by Recordati Rare Diseases is stored in a central CRM database and will be retained in accordance with the applicable retention policies.

 

Cross-border data management

Recordati Rare Diseases UK Ltd may transfer personal data held in the UK to RECORDATI RARE DISEASES, Société à Responsabilité Limitée located in France if required for the purposes set out above under “Data processing activity purpose”.

 

Data Subject rights

Under the Data Protection Legislation and in certain circumstances, you as a Data Subject have the right to:

  • Request Access: to personal information that Recordati Rare Diseases holds about you.  This includes a right for you to receive a copy of the personal information Recordati Rare Diseases holds about you, and to check Recordati Rare Diseases are lawfully using it.
  • Request Rectification: of your personal information if you become aware of any inaccuracies in your personal information which Recordati Rare Diseases use.
  • Request Erasure: of your personal information where (a) there is no good reason for us continuing to use your personal information as described in our Notices, (b) Recordati Rare Diseases rely on your consent and you have withdrawn it, (c) you have exercised your right to object to our use of it (see below) and no exception permits us to keep using it, (d) it is established that Recordati Rare Diseases did not have a lawful right to use your personal information, or (e) the law requires us to erase your personal information.
  • Object: to the use of your personal information.  You can exercise this right if Recordati Rare Diseases rely on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to the use of your personal information on this ground, if there is no exception which applies to permit us to keep using it.
  • Stop: us carrying our profiling for our direct marketing purposes, or stop us sending direct marketing to you.
  • Restriction of processing: of our use of your personal information.  This enables you to ask us to suspend our use of your personal information, for example if you want us to establish its accuracy or the reason for us using it, or you consider Recordati Rare Diseases no longer needs to use your personal information for the purposes for which it was collected or used (but you want it to be preserved).  You may also ask us to restrict use if you exercise your right to object to our use of your personal information and no exception applies to permit us to keep using it.
  • Withdraw your consent: if we rely on your consent as our legal basis for Recordati Rare Diseases using your personal information.
  • Complain to the ICO: the Information Commissioner’s Office is the personal information regulator in the UK. See www.ico.org.uk for details.
     

Notice update


This notice may be subject to amendments and additions, which will be communicated promptly.