Privacy policy

This Privacy Policy aims to inform Users that are subject to it ,about the potential processing of their personal data pursuant to the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereafter, the “GDPR”) and Organic Law 3/2018 of 5 December on Personal Data Protection and the Guarantee of Digital Rights (hereafter, “LOPDGDD” -Spanish acronym-) as well as other applicable regulations.
 

FERRER may process your personal data when you visit the www.ferrer.com website or any other domain or subdomain owned by FERRER, (hereafter, the “Site” or the “Website”), FERRER’s Social Media profiles (Instagram, Facebook, Twitter, etc.) or when you contact FERRER through the Website.
 

This privacy explains which data FERRER collectcollects and what is done with said data. Subsequently, among other items, this Privacy Policy aims to explain the following

1. the information that is collectcollected by FERRER and the purpose;

2. the use FERRER makes of said information;

3. the options FERRER offers in regard to the information compiled.

For the purposes of this Policy, a “User” shall mean any category of data subject included in this document.

1.Details of the Controller:

 

As Controller, GRUPO FERRER INTERNACIONAL S.A. (hereafter, “FERRER”) takes the privacy of its Users very seriously and commits to doing whatever is in its power to respect it.

FERRER’s identifying details are as follows:

Owner: GRUPO FERRER INTERNACIONAL, S.A..

Registered address: Avenida Diagonal, nº 549, 5ª Planta, 08029, Barcelona (Spain)

C.I.F. (Corporate ID): A61738993

Contact: lopd@ferrer.com

DPO contact: dpo@ferrer.com

Telephone No.: 936 003 700

2.Personal data processed

 

FERRER collectcollects personal data as follows:

1. Personal data provided by the User: when you fill in forms on the Website, physical forms or through any of the FERRER Social Media profiles.

2. Personal data have not been provided form the User: occasionally, FERRER collaborates with institutions like IQVIA Information, S.A. to obtain User contact details, specifically regarding healthcare professionals. Similarly, data from interactions with healthcare professionals may be obtained, including, for instance, doctor’s appointments, delivery of medication and healthcare products. In any event, Users shall be informed of this. 

3. Through Cookies and similar technologies: FERRER uses different technologies to collect and store information when you visit its Website, including cookies or similar technologies that identify your browser or device. FERRER also uses these technologies to collect and store information when you interact with services offered by FERRER or other Google functionalities that may appear in other web sites. Google Analytics helps FERRER analyse the Website’s traffic. Please read our Cookies Policy for more information about FERRER’s processing of personal data obtained by Cookies.

In general terms, personal data may be grouped into the following categories:
 

Identification data: name, surnames, gender, DNI (Spanish national ID) or NIF (Fiscal ID), address and e-mail, telephone number, manual and/or electronic signature, marital status, image, voice, Social Security No. or mutual insurance membership.

Healthcare data: medical details and interactions (such as the delivery of medication and sanitary products), as well as a description of adverse reactions to medication.

Economic Data: medical fees and sponsorship for healthcare professionals to attend scientific initiatives. 

Professional and academic data: qualifications, language proficiency levels, medical speciality, medical subspecialities, résumé, company or medical centre where you work, post, obligations.

Data for profiling: interests, hobbies. 

Connection - identifying data: IP, logs.

Furthermore, we process personal data pertaining to different data subject categories, considered as Users as a whole, including, but not limited to the following: 

Website and Social Media Users: personal data pertaining to Users that have contacted FERRER through the Website, or that follow us or subscribe to any of our Social Media platforms.

Healthcare professionals: personal data provided by IQVIA Information S.A. or by the data subjectsdata subjects who, in their capacity as healthcare professionals, contact FERRER through the Website to request information and/or to ask questions, which may be medical in nature, or who communicate to inform of adverse reactions linked to pharmacovigilance.

Patients or Consumers: personal data pertaining to data subjects that contact FERRER through our Website to request information and/or to ask questions, which may be medical in nature, or who communicate to inform of adverse reactions linked to pharmacovigilance.

Notifying third parties: personal data pertaining to data subjects that are not those contacting FERRER through the Website to request information and/or to ask questions, which may be medical in nature, or who communicate to inform of adverse reactions linked to pharmacovigilance. 

Job applicants: personal details pertaining to individuals applying for work at FERRER directly through our Website and/or in collaboration with third parties managing job offers or applications.

Clients, suppliers or collaborators: personal data pertaining to data subjects who, in their capacity as clients, service providers or any kind or collaborators, contacting FERRER through the Website to enter into strategic alliances or to pursue business opportunities, including, but not limited to, FERRER in-license or out-license activities in specific therapeutic areas, requests for technical support and/or diagnosis services.

3.Processing Purpose, Legal basis and Storage Period of the Personal Data

 

As mentioned previously, FERRER shall process the personal data obtained through different channels. Similarly, FERRER shall process these personal data according to the different data subject categories and purposes

3.1 Processing purpose of FERRER Website and/or subdomain User data

The personal data collected through the FERRER Website shall be processed for the following purposes

1. To attend to User requests for information and/or queries.  

2. Storage period: until such a time as the User’s request for information and/or query have been resolved, and once resolved, for however long is needed to meet with the applicable legal obligations, if any.

   Legal basis: the consent provided by the User is implicit in their request and/or query, as the purpose is to allow FERRER to attend  it.

3. Allowing for the use of the features placed at their disposal through the Website, including, but not limited to, quality complaints, requests for scientific bibliography and/or information pertaining to healthcare products. 

4. Storage period: until such a time as the User’s request for information and/or question have been resolved, and once resolved, during the amount of time needed to meet with the applicable legal obligations, if any.

   Legal basis: the consent provided by the User is implicit in their request and/or query, as the purpose is to allow FERRER to attend +¡ it.

5. Allowing for participation in activities suggested by FERRER, such as Ferrer 4 Future. 

6. Storage period: while the relationship between the User and FERRER lasts. Once this time has elapsed, for however long is needed to meet with the applicable legal obligations.

   Legal basis: the correct execution of the conditions of participation in said activities agreed on between the User and FERRER in the corresponding Website, for instance, the conditions of use.

3.2 Processing purpose of Healthcare Professional data

The personal data collected by FERRER shall be processed for the following purposes

1. Managing the relationship with healthcare professionals. 

   Storage period: until the relationship has come to an end and once the time needed to fulfil any legal obligations has elapsed.  

   Legal basis: the execution of contractual obligations. 

2. In the case of personal data provided in order to notify adverse reactions related to medication, FERRER shall process the data exclusively for pharmacovigilance purposes, and solely when pertinent in order to document and correctly manage the response for the data subject, as well as to report the adverse reaction to the responsible authorities pursuant to pharmacovigilance obligations. 

3. Storage period: the data shall be stored for a period of 10 years after the removal of the medication from the last remaining country where it is marketed.

   Legal basis: fulfilment of FERRER’s legal obligations in regard to the communication of adverse reactions.

4. As for personal data provided upon attending a doctor’s appointment, FERRER shall process the data solely for the purposes of adequately managing the response given to the healthcare professional. 

5. Storage period: a minimum of 10 years and a maximum of 15 years after having received it..

   Legal basis: the fulfilment of FERRER’s legal obligations.

6. Maintaining relationships with the legal entity where the data subject works, as well as with healthcare professionals considered independent entrepreneurs or liberal professionals in order to establish a professional relationship, and not as individuals coming into contact, for instance, by means of doctor’s appointments with the intention of providing information and training about our products and services. 

7. Storage period: until such a time as the data subject objects to receiving communications. 

   Legal basis: FERRER’s legitimate interest pursuant to article 19 of the LOPDGDD due to being limited to the processing of the necessary data to establish their professional location and to maintain a commercial relationship.  

8. Meeting with transparency requirements relating to transfers of value to healthcare professionals, and FERRER would further like to inform you that it shall individually publish any and all transfers of value to healthcare professional carried out by FERRER (whether direct or indirectly) on the Website. 

9. Storage period: the aforementioned data shall remain published for a period of thee (3) years from publication, unless a shorter time period is legally established. FERRER shall store the documents for a period of five (5) years, after which they shall be deleted.

   Legal basis: FERRER’s legitimate interest pursuant to the Spanish Data Protection Agency report of 22 April 2016 and the Pharmaceutical Industry’s Code of Good Practices

3.3. Processing purpose for Patient or Consumer data

The personal data obtained by FERRER shall be processed for the following purposes

1. In the case of personal data provided in order to notify adverse reactions related to medication, FERRER shall process the data exclusively for pharmacovigilance purposes, and solely when pertinent in order to document and correctly manage the response for the data subject, as well as to report the adverse reaction to the responsible authorities pursuant to pharmacovigilance obligations. 

2. Storage period: the data shall be stored until a response has been given to the data subject, the case has been documented and the adverse reaction has been informed to Pharmacovigilance and the responsible authorities.

   Legal basis: explicit consent granted by you when ticking the correct box.    

3. In the case of the personal data provided, including details about health, on sending medical consultations, FERRER shall process the data exclusively in order to attend to requests for information and/or queries carried out by the patient. 

4. Storage period: the data shall be stored until such a time as the data subject has received a reply and the case has been documented.

5. Legal basis: explicit consent granted by you when ticking the correct box.    

6. In the case of the personal data provided, including details about health, on sending quality complaints, FERRER shall process the data exclusively to attend to requests relating to quality complaints. 

7. Storage period: the data shall be stored until such a time as the data subject has received a reply and the case has been documented.

   Legal basis: explicit consent granted by you when ticking the correct box.    

3.4 Processing purpose of Notifier data

1. In the case of personal data provided in order to notify adverse reactions related to medication, FERRER shall process the data exclusively for pharmacovigilance purposes, and solely when pertinent in order to document and correctly manage the response for the data subject, as well as to report the adverse reaction to the responsible authorities pursuant to pharmacovigilance obligations. 

2. Storage period: the data shall be stored until a response has been given to the data subject, the case has been documented and the adverse reaction has been informed to Pharmacovigilance and the responsible authorities.

   Legal basis: fulfilment of FERRER’s legal obligations in regard to the communication of adverse reactions. 

3.5 Processing purpose of Job applicant data

1. Should the User send FERRER their résumé and/or a job application, their data shall be processed to attend to said request, and if appropriate, to allow them to partake of the selection process for a position at FERRER. 

2. Storage period: all résumés are destroyed once a year has elapsed since the end of the aforementioned selection process, due to which should the User wish to remain in the FERRER database, they must send their résumé once again once the period has elapsed.

   Legal basis: consent by the User is implicit when sending the résumé and/or job application.

3.6 Processing purpose of client, supplier and collaborator data 

1. To inform the User about FERRER business developments; to engage in strategic alliances or to pursue business opportunities, including, but not limited to, FERRER in-license or out-license activities in specific therapeutic areas, requests for technical support and/or oncological diagnosis services offered through the Website.

2. Storage period: until such a time as the data subject objects to receiving said communications.

   Legal basis: FERRER’s legitimate interest pursuant to article 19 of the LOPDGDD due to processing being limited to the data needed to establish their professional location and to conduct professional relationships.   

3. Maintaining relationships with the legal entity where the data subject works and with individual entrepreneurs or liberal professionals to establish a professional relationship, but not as data subjects. 

4. Storage period: until such a time as the data subject objects to receiving communications. 

   Legal basis: FERRER’s legitimate interest pursuant to article 19 of the LOPDGDD due to processing being limited to the data needed to establish their professional location and to conduct professional relationships.  

5. Keeping FERRER’s clients informed (including by electronic means) about FERRER products, services or novelties based on products and services that are similar to those contracted by the user. 

6. Storage period: until such a time as the data subject objects to receiving communications. Furthermore, at the time of contracting products and/or services, the user shall have at his or her disposal a mechanism for opposition to this kind of commercial activity. 

   Legal basis: FERRER’s legitimate interest pursuant to article 21.2 of Law 34/2002 of 11 July on information society services and e-commerce (LSSI -Spanish acronym-) on account of the existence of a prior contractual relationship by means of which FERRER lawfully acquired its clients’ contact data to use for sending commercial communications referring to products or services similar to those that were initially the object of their contracting.

3.7 Processing purpose of Social Media User personal data

1. Managing interactions between the User and FERRER by means of the different Social Media platforms (Instagram, Facebook, Twitter, etc.). The data processed to this end shall be those entered by the Users in the corresponding social media profile, which are regulated by that social media platform’s Privacy Policy, for which FERRER is not responsible.

2. Storage period: the data processed for this purpose shall be stored while FERRER’s profile on the social media platform remains active.

   Legal basis: implicit consent provided by the data subject upon interacting with and/or following FERRER’s profile on that social media platform

3.8 Processing purposes for all the previous data subject categories 

1. Keeping the data subject informed (including by electronic means) of FERRER products, services, novelties, publications, invitations, programmes, newsletters, activities and events, provided the User has expressly consented to said processing. 

2. Storage period: until such a time as the data subject withdraws consent for receipt of said communications.

3. Legal basis:

   1. Express consent provided by the data subject for receiving said communications.

   2. Express consent provided by the service provider duly collected by IQVIA Information, S.A., should it relate to personal data collectcollected by FERRER from it.

4.Recipients

 

Pursuant to the stipulations of the purposes for processing expressed in the previous section, the personal contact details of Website Users, applicants, clients, suppliers or collaborators, shall be communicated to FERRER Group companies provided express consent has been granted to this end, otherwise, based on FERRER’s legitimate interest for internal administrative purposes in line with what is foreseen in statement 48 of the GDPR relating to clients and applicants. You may view data pertaining to FERRER Group companies by writing to the e-mail address lopd@ferrer.com.

Additionally, please note that personal data pertaining to healthcare professionals, patients or notifying third parties shall be communicated to the Spanish Pharmacovigilance System for Human Use Medication (SEFV-H -Spanish acronym-) in the event of adverse reactions.

Furthermore, we would like to inform you that your personal data may be accessed by third parties representing FERRER, provided this access and processing is essential for providing a specific service to FERRER. In this scenario, FERRER must enter into the corresponding data processor agreement with each of these third parties, who shall process the data exclusively for the ends FERRER establishes in each case

5.International transfers

 

For some services, the personal data pertaining to certain categories of data subjects may be subject to processing, access or storage in a country other than the country in which FERRER is established and that may not offer the same level of protection in regard to the personal data.  

Should FERRER transfer personal data to companies in jurisdictions outside the European Economic Area, it shall guarantee their protection by (i) applying the required level of protection according to local legislation about data protection/privacy applicable to FERRER, (ii) acting in compliance with FERRER regulations and policies, (iii) FERRER being within the European Economic Area (that is to say, UE member states plus Iceland, Liechtenstein and Norway, the “EEA”), unless otherwise stated, exclusively transferring personal data as per the standard contractual clauses approved by the European Commission, and (iv) to sum up, should consent by the data subject be the Legal basis for the processing. 

You may request additional information about international personal data transfers and a copy of the duly implemented protection measures in keeping with the exercise of your rights as detailed as follows in section 7 (Rights)

6.Security and access 

 

Pursuant to the GDPR and the LOPDGDD, FERRER declares that  applies any and all technical, administrative and organisational measures to protect the personal data we collect against accidental or illicit destruction, alteration, disclosure or unauthorised access, especially when the processing implies the transmission of data over a network and in regard to any other illicit form of processing.

Generally speaking, Users are not required to register before accessing and browsing Website content. Nevertheless, registration may be required to view certain Social Media content. In this case, the data entered by the User must be exact and up to date, and the Social Media’s Privacy Policy must be complied with.

7.Rights

 

FERRER guarantees the following personal data rights for its Users: access, rectification, erasure, limitation, portability and opposition.

Similarly, regarding the processing of User data where the Legal basis is based on consent granted by data subjects, the data subjects shall be within their right to withdraw said consent at any time, however, this shall not affect legitimate processing based on consent given prior to having withdrawn it.

In order to exercise these rights, data subjects must send a written request, attaching identifying documents and/or information, and specifying the right they wish to exercise as detailed previously.

1. Via e-mail to lopd@ferrer.com

2. By post to GRUPO FERRER INTERNACIONAL S.A. to the following address: Av. Avenida Diagonal, nº 549, 5ª Planta, 08029, Barcelona (Spain)

We shall consider all requests and issue our reply within the time period established by applicable law. Please take into account, however, that certain information may not be affected by these requests under certain circumstances, namely in regard to personal data that we may have to continue processing in line with our legitimate interests or to meet with legal obligations.

In any event, Users are within their right to file a complaint before the competent supervisory authority, should they deem it necessary.

Should you have any queries in regard to the processing of FERRER personal data, you may contact our Personal Data Officer by writing to the following e-mail address: dpo@ferrer.com 

8.Changes or modifications to our privacy policy

 

We may occasionally modify this privacy Policy and publish the latest version on our Website. We shall inform you in the event your rights are substantially affected as a consequence of one such modification