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Last update: July 2021

 

In accordance with the applicable data protection regulation, the purpose of this privacy policy is to help the data subject to understand what type of personal data LACER S.A. (hereinafter “LACER”) collects, as well as the manner or way LACER processes these personal data.

 

1. DATA CONTROLLER

 

LACER, S.A., with registered office at C/Boters 5, 08290 – Cerdanyola del Vallès (Barcelona), Spain.

 

2. DATA PROTECTION OFFICER

 

You may contact our Data Protection Officer at Lacer´s postal address, as well as through the email address:  dataprotection@lacer.es

 

3. HOW WE OBTAIN YOUR PERSONAL DATA

 

Personal data processed will be the data that you provide to us through the various channels that LACER makes available to you.

 

Likewise, by visiting LACER´s website, various technologies are used in order to collect and store information, including the use of cookies or similar technologies to identify your browser or specific device. LACER uses these technologies to collect and store information, too, when you interact with those services provided by LACER.

 

To obtain additional information about LACER´s processing of personal data obtained through the use of cookies, please access the following link: Cookies´policy.

 

4. CATEGORIES OF DATA, PURPOSES AND LEGAL BASIS REGARDING THE PROCESSING OF PERSONAL DATA PROCESSED BY LACER AS DATA CONTROLLER

 

QUERIES´S ATTENDANCE
CATEGORIES OF PERSONAL DATA PURPOSES LEGAL BASIS
The following personal data are processed:

§  Identity data  (name and surnames),

§  Contact data  (email-address)

§  Subject of the inquiry

 

Data processing for the purpose of responding and attending to your inquiry at the moment you contact us.

 

 

 

The processing of your personal data related to the maintenance of your relationship with LACER as the person sending a request for information is legitimate as it is necessary in order to comply with the contractual or pre-contractual obligations established in the Website’s Legal Notice.

 

COMPLIANCE WITH LEGAL OBLIGATIONS
CATEGORIES OF PERSONAL DATA PURPOSE LEGAL BASIS
The following personal data are processed:

§   Identity data  (name and surnames)

§  Contact data  (email-address)

§  Subject of the inquiry

 

We process your personal data in order to comply with applicable legal obligations regarding adverse reaction reporting.

In particular to:

 

§  Identify the data subject who has reported the case and carry out an adequate follow-up of the reported case;

 

§  Analyze and send to the healthcare authorities, information about suspected adverse reactions that you have reported to us, as well as follow up on the report/case.

 

Processing is necessary for compliance with a legal obligation to which we, as pharmaceutical company, are subject to.
SOCIAL MEDIA PROCESSING
LACER has social networks profiles (such as Facebook or Instagram) and may act as joint controller together with FACEBOOK IRELAND LTD., with registered office at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereinafter “FACEBOOK”). LACER may act as joint controller together with FACEBOOK in those processing covered by the FACEBOOK´s appendix for controllers accesible at:  https://www.facebook.com/legal/controller_addendum

 

LACER and FACEBOOK have entered into a controller agreement, in order to determine their respective responsibilities and duties for compliance with their obligations under data protection law with respect to joint processing (as specified in the applicable product terms and conditions).

 

For additional information on processing of data by FACEBOOK, please refer to FACEBOOK´s privacy policy: https://www.facebook.com/about/privacy

Likewise, we also inform you that we cannot be held responsible for the processing of peronal data by FACEBOOK. Accordingly, LACER will only be responsible for its own data processing, properly described in this clause.

CATEGORIES OF PERSONAL DATA PURPOSES LEGAL BASIS
The following personal data are processed:

 

§  Identity data  (name and surnames)

§  Contact data  (email-address)

§  Social´s network ID account

 

Processing of personal data in order to manage interactions and communications  between the data subject and LACER, through the information provided by the data subject on social networks where LACER has an active profile.

 

In addition, FACEBOOK processes your personal data as specified in the applicable product terms and conditions. Additional information regarding FACEBOOK´s personal data processing, including personal data tipology, purposes, and legal basis on which FACEBOOK relies, can be found in FACEBOOK’s privacy policy: https://www.facebook.com/about/privacy

 

The processing of your personal data is legitimate as it is necessary to comply with the contractual or pre-contractual obligations established in the terms and conditions applicable to each LACER´s active profile in third parties social networks.

 

5. NECESSARY NATURE OF THE REQUESTED DATA

 

The personal data marked with an asterisk (*) on the website will be necessary to fulfill the established purpose. Therefore, if the user does not provide them, we will not be able to attend his or her request.

 

6. AUTOMATED INDIVIDUAL DECISION-MAKING

 

LACER does not adopt any decision affecting data subject´s personal based solely on automated processing, including profiling.

 

7. WHEN AND FOR WHAT REASON WE MAY PROVIDE YOUR DATA TO THIRD PARTIES

 

Your data may be disclosed to following recipients, for the purposes explained below:

 

  • Public administrations: for compliance with legal obligations to which LACER is subject due to its main activity. In particular, competent healthcare authorities when so required by current and applicable legislation.
  • Licensing partners and other third parties (such as medical professionals and other companies involved in the marketing of products subject to adverse event reporting) to whom applicable regulations require to report and communicate adverse events.
  • Suppliers who need access to your personal data for the provision of services that LACER has contracted with them, and with whom LACER has signed the required and necessary confidentiality and personal data processing agreements by law, in order to protect your privacy and personal data.

 

If, in the future, LACER carries out additional personal data transfers (like the ones explained in the abovementioned paragraph), LACER will duly inform you.

 

8. INTERNATIONAL DATA TRANSFERS

 

LACER may contract the services of suppliers located in countries outside the European Economic Area, based on the European Commission’s decisions of adequacy. In this case, it is considered that the country has regulations equivalent to European regulations. In the event that LACER needs to contract services from suppliers located in countries that do not have regulations equivalent to those of the European Union, its contracting shall include all the guarantees and safeguards required by the regulations in order to preserve your privacy, after verification of the destination´s country legislation. Such safeguards may consist of the application of contractual clauses and additional guarantees to them, in accordance with the regulations of each destination country. They may also consist of binding corporate rules approved by the data protection authorities. In addition, we also inform you that data protection regulations allow us to send your personal data to such countries, if such transfers are necessary to comply with our obligations arising from the services requested by you.

 

The following company will have access to the personal information necessary to perform its functions and tasks as data processor, but may not process it for other purposes. In addition, it must process personal information in accordance with this privacy policy and applicable data protection legislation.

 

Google Analytics: an analytical web service provided by Google, Inc. It is a Delaware company headquartered at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, United States (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help LACER analyze how users use its own website. The information generated by the cookie about your navigation in LACERs, website (including your IP address) will be transmitted to and stored by Google on servers located in the United States.

 

If you are interested in acquiring additional information about the applicable guarantees to your privacy, as well as about the destination countries to which we need to transfer your personal data in order to fulfill our contractual obligations with you, you can contact our data protection officer through the addresses referred in the “Data Protection Officer” section of this privacy policy.

 

9. RETENTION OF YOUR PERSONAL DATA

 

Your personal data will be kept up as long as your relationship with LACER is maintained and, after the termination of such relationship for any reason, your personal data will be maintained during the applicable legal statute of limitations. In this case, they will be processed for the sole purpose of proving compliance with our legal or contractual obligations. At the end of such storage period, your data will be deleted or, alternatively, anonymized.

 

10. YOUR RIGHST REGARDING PERSONAL DATA PROTECTION

 

You may exercise your rights of access, rectification, erasure and portability, restriction and/or opposition to the processing, through the postal and email address indicated in the “data protection officer” section of this privacy policy.

 

Likewise, if you consider that the processing of your personal data violates the regulations or your privacy rights, you can file a complaint:

 

  • Before our Data Protection Officer, through the postal and e-mail addresses indicated.
  • Before the Spanish Data Protection Agency, through its electronic platform, or its postal address.

 

11. CODE OF CONDUCT FOR DATA PROTECTION IN THE ADVERTISING ACTIVITY OF AUTOCONTROL

 

LACER adheres to AUTOCONTROL’s Code of Conduct on Data Protection in the Advertising Activity, accredited by the Spanish Data Protection Agency. Consequently, we inform you that LACER is subject to AUTOCONTROL’s out-of-court complaint handling system for complaints related to data protection and advertising. Further information is available to interested parties on the website www.autocontrol.es.