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Privacy policy

 

Privacy Policy

Dear User!

In order to ensure the highest possible standard of protection of your personal data, we have prepared this Privacy Policy. In this document you will find the principles on which the processing of personal data is based when using our website, as well as how cookies work. We kindly ask you to read this information if you use our website.

 

Contents:

  1. Definitions
  2. Introduction
  3. Personal data and the purposes of their processing
  4. The requirement to provide data and the legal basis for the processing of personal data
  5. Period of time for which personal data will be processed
  6. Recipient of personal data
  7. Cookies files - types of cookies, how long they are stored and how to withdraw consent to their installation
  8. Social media plugins
  9. Transfers of personal data to third countries
  10. Users rights
  11. Final provisions

 

1. Definitions

1.1. Website  –  the website https://www.polfarmex.pl  operated by Polfarmex S.A. with its registered office in Kutno, 9 Józefów Street, 99-300 Kutno.

1.2. GDPR – General Data Protection Regulation, its Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC 

1.3. Data Controller - the entity that determines the purposes and means of processing personal data within the meaning of Article 4(7) of the GDPR, the data Controller of website users is Polfarmex S.A. with its registered office in Kutno, 9 Józefów Street, 99-300 Kutno.

1.4. Foundation - Wośko Family Foundation with registered office in Siemienice, Siemienice 18, 99-314 Krzyżanów.

1.5. User - any person visiting the Polfarmex S.A. website.

1.6. Personal data - means any information about an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person (as defined in Article 4(1) of the GDPR).

1.7. Cookies files - are small text files stored on your computer or mobile device when you use the Website.

 

2. Introduction

2.1. Maintaining confidentiality, data protection and respecting the rights of data subjects are of utmost importance to Polfarmex S.A. and we want each person whose data we process to know that we comply with the requirements arising from the GDPR. Therefore, Polfarmex S.A. applies appropriate data protection measures as well as monitors data security on an ongoing basis and actively responds to identified threats and responds to any requests from data subjects.

2.2. The security of personal data should be understood as ensuring their confidentiality, integrity, availability and accountability, through the implementation and operation of technical mechanisms and organizational procedures necessary for this purpose.

2.3. The purpose of presenting this information is to protect the interests of data subjects by providing access to the necessary information and enabling the exercise of the rights which any person whose personal data are processed by the Polfarmex S.A. website is entitled to.

 

3. Personal data and the purposes of their processing

3.1. Personal data, depending on individual needs, will be processed for the following purposes:

1) receiving and processing applications to Polfarmex S.A. and to the Foundation,

2) Correspondence, replies to questions and requests addressed to Polfarmex S.A. and the Foundation,

3) receive and record reports on adverse reactions to medicinal products and forward this information to the appropriate authority,

4) conduct staff recruitment.

 

4. The requirement to provide data and the legal basis for the processing of personal data

4.1. The processing of personal data is necessary to achieve the above mentioned purposes, however, the data is provided on a voluntary basis.

4.2. The legal basis for the processing of personal data will be Article 6 (1)(f) of the GDPR, when data will be processed in the legitimate interest of Polfarmex S.A. The legitimate interest of Polfarmex S.A. is the handling of correspondence conducted via dedicated contact forms on the Polfarmex S.A website (point 3.1. pp. 1-2).

4.3. Due to the nature of the Company's business, the legal basis for the processing of personal data will also be the performance of the Company's obligations under the law (Article 6(1)(c) of GDPR), such as receiving reports and recording adverse drug reactions. The legal basis for the processing is the provisions of Article 9(2)(i) of the GDPR, i.e. the processing is necessary for reasons of public interest in the field of public health in the form of ensuring high standards of quality and safety of medicinal products. The legal obligation arises from Article 36d, Article 36e Article 36g of the Act of 6 September 2001. Pharmaceutical Law (i.e. Journal of Laws of 2021, i.e. 1977). Providing data is necessary for the implementation of the aforementioned legal obligations incumbent on the administrator, without providing the required data it is not possible to accept and register the application. (point 3.1. subpoint 3).

4.4. Personal data processed for the purposes of the recruitment process (point 3.1. subpoint 4), will be processed on the basis of Article 221 of the Labour Code (Journal of Laws 2020, item 1320) (hereinafter: Labour Code) and on the basis of a freely given consent of a candidate who applies for a given position. In the event that the candidate provides a broader range of data in the application form than provided for in Article 221 of the Labour Code, the basis for the processing of his/her personal data will be Article 6.(1)(a) of the GDPR, i.e. the data will be processed on the basis of the consent expressed by voluntarily sending additional information.

4.5. The legal basis for the processing of personal data for the purposes of recruitment (point 3.1. subpoint 4) in relation to cooperation on the basis of civil law contracts will be Article 6(1)(b) of the GDPR - data are processed for the purpose of entering into and performing an agreement and on the basis of Article 6(1)(f) of the GDPR - data are processed in the legitimate interest of the controller, the legitimate interest of Polfarmex S.A. is cooperation and communication in order to properly perform the agreement.

 

5. Period of time for which personal data will be processed

5.1. Personal data processed for the purpose of correspondence and responding to inquiries will be deleted successively after their usefulness has ceased (point 3.1.1 - 2).

5.2. Personal data relating to persons reporting adverse drug reactions (point 3.1.3) shall be processed for the duration of the marketing authorisation of the medicinal product and for 10 years starting from its expiration date.

5.3. Personal data processed for the purpose of participation in staff recruitment (point 3.1. subpoint 4) will be processed for the duration of the respective recruitment process and will be deleted no later than 1 month after its completion.  In the case of expressing consent to use the data in future recruitment processes, the data will be processed until the withdrawal of consent,  but no longer than for a period of 24 months from the date of sending the application documents to Polfarmex S.A. The withdrawal of consent does not affect the legality of processing, which was performed on the basis of consent before its withdrawal.

 

6. Recipient of personal data

6.1. Polfarmex S.A. transfers personal data to other entities entrusted with the processing of personal data on behalf of and for the benefit of the Company. Personal data is entrusted for processing only to entities that ensure appropriate data protection standards in accordance with the requirements of art. 28 GDPR.

6.2. Moreover, Polfarmex S.A. provides personal data to entities providing postal and courier services. In the event of pursuing claims, the data will be made available to a law firm, courts, court bailiffs or entities conducting debt collection activities.

6.3. When it is dictated by a legal obligation, personal data will also be made available to the competent Tax Office, the Social Insurance Institution, pursuant on the basis of Article 6(1)(c) of the GDPR, but only to the extent necessary, indicated in the relevant provisions of law. In the event that such an obligation will result from legal provisions, personal data may be made available to courts, the prosecutor's office, the Police, the National Revenue Administration, the Border Guard, the Internal Security Agency or Central anti-corruption office.

6.4. Polfarmex S.A. as part of the legal obligation related to the administration and registration of adverse drug reactions, it provides personal data to the European Medicines Agency. Other personal data are not transferred to third countries and international organizations.

 

7. Cookies files - types of cookies, how long they are stored and how to withdraw consent to their installation

7.1. Polfarmex S.A. in accordance with the provisions of Article 173 and 174 of the Act of 16 July 2004 - the Telecommunications The law (Journal of Laws of 2004, No. 171, item 1800, as amended), informs that the Website uses "cookie" technology as part of its operation. Cookies are small text files stored on your computer or mobile device when you use the Website.

7.2. The website uses the following cookies:

a) "Technical" cookies - these are cookies that are absolutely necessary for the proper functioning of the Website and the proper delivery of the services you have requested, as well as for storing your consent to other categories of cookies. You can disable them in your browser settings, but this may affect the functioning of the Website

b) "Analytical" cookies - these are cookies that are installed by Google Analytics. They are used to improve our website by collecting and presenting information about how you use it. The cookies collect information in a way that does not directly identify individuals. The installation of analytical cookies on your end device requires your consent.

 

Cookie Domain type Type of cookies Description Storage time
_ga .polfarmex.pl Analytical The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and tracks site usage for the site analytics report. 2 years
_gid .polfarmex.pl Analytical

The _gid cookie, installed by Google Analytics, stores information about how visitors use the site and creates an analytics report on site performance. Some of the data collected includes the number of visitors, their source, and the anonymous pages they visit.

1 day
PHPSESSID www.polfarmex.pl Technical

This cookie is native to PHP applications. This cookie is used to store and identify a unique user session ID in order to manage the user's session on the site. This cookie is a session cookie and is deleted when all browser windows are closed.

During the session
_gat .polfarmex.pl Analytical

This cookie is installed by Google Universal Analytics to limit the number of queries and thus limit data collection on high traffic sites.

1 minute

 

7.4. If User doesn't want to save cookies files, he can change his browser settings. It should be noted, however, that disabling cookies necessary for authentication processes, security, maintenance of User preferences, may hinder, and in extreme cases, prevent the use of the Website.

Ways to configure cookie settings in individual search engines can be found, among others at the following addresses:

a) Firefox (https://support.mozilla.org/en-US/kb/third-party-cookies-firefox-tracking-protection)

b) Chrome (https://support.google.com/chrome/answer/95647?hl=en&co=GENIE.Platform%3DDesktop)  

c) Internet Explorer (https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d) 

d) Microsoft Edge (https://support.microsoft.com/en-us/search?query=enable%20cookies%20in%20edge) 

e) Safari (https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac)

 

8. Social media plugins

8.1. On the website of Polfarmex S.A, plugins for the social network Facebook (provider Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA) and LinkedIn (LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA) have been integrated.

8.2. After clicking on the Facebook and LinkedIn plug-in icons, the user is sent to the above-mentioned portals. Then it has the ability to like, comment and share posts available on the Polfarmex S.A. profile. on the above-mentioned portals.

8.3. Polfarmex S.A. has no influence on the data processed by Facebook and LinkedIn. From the moment the User clicks the button of the plugin referring to Facebook and LinkedIn, personal data is processed by the above-mentioned portals, which become their data controller and decide on the purposes and scope of their processing. Cookies files left by Facebook and LinkedIn plugins (or other third parties) may also be installed on the User's device after entering the website, and then associated with data collected on Facebook and LinkedIn.

8.4. If the User has an account on Facebook and LinkedIn social networks and does not want them to collect information about him via the Polfarmex S.A. Website or link it with data already stored by Facebook and LinkedIn, then he must close the Polfarmex S.A. website, log out of the account on the above-mentioned portals, and then re-enter the Polfarmex S.A. website.

 

9. Transfers of personal data to third countries

9.1. Due to the use on the Website of services provided by entities based outside the European Union or the European Economic Area, Polfarmex S.A. transfers personal data to third countries. This transfer of personal data takes place only if, with respect to that third country, the European Commission has confirmed an adequate level of data protection or an adequate level of data protection has been agreed with the data recipient (e.g. using the so-called standard contractual clauses). 

 

10. Users rights

10.1. The person whose personal data is processed by Polfarmex S.A. has the right to:

a) to access their personal data and receive a copy of the personal data being processed pursuant to Article 15 of the GDPR;

b) to rectify its incorrect data in the cases indicated in Article 16 of the GDPR;

c) to request erasure of data (right to be forgotten) in the event of the circumstances provided for in Article 17 of the GDPR;

d) to request the restriction of data processing in the cases indicated in Article 18 of the GDPR;

e) to transfer the provided personal data, processed by automated means in the cases referred to in Article 20 of the GDPR;

f) to object to the processing of your personal data, in the cases referred to in Article 21 of the GDPR.

10.2. Polfarmex S.A. informs that it is possible to refuse to delete personal data in cases where Polfarmex S.A. is obliged to process this data imposed by the provisions of Polish or EU law, or the processing is related to the investigation or defense of claims.

10.3. Any person who considers their personal data to be unlawfully processed may lodge a complaint with a supervisory authority (UODO, Stawki 2 street, Warsaw).

 

11. Final provisions

11.1. The Privacy Policy applies to data processing by Polfarmex S.A. to the website https://www.polfarmex.pl 

11.2. The Data Protection Officer can be contacted by sending a letter to the above address or by sending an email to: iod@polfarmex.pl 

11.3. This privacy policy is regularly verified and, if necessary, updated. The current version of the policy has been adopted and is effective as of 31 may 2022 r.