Privacy Policy

GL Pharma takes data protection extraordinarily seriously. We process personal data only in compliance with data protection regulations.

We process personal data only for previously defined purposes and ensure that the data is correct and up to date. Personal data that is no longer needed for the defined purpose or incorrect will be deleted immediately. Furthermore, we ensure adequate security of the data processed by us and protect it against unauthorized access.

Which personal data is processed by G.L. Pharma GmbH and for what purpose? To whom is the personal data transferred to?

Processing purpose “website“:

With the exception of the cookies described below, no personal data is collected when visiting all freely accessible G.L. Pharma websites. Password-protected areas require the collection and storage of personal data in the course of registration. We process the following personal data of registered users of our websites: name, contact details. The reason for this is that users can use the log-in section of our websites as well as the related services. The legal reason for the processing is the consent of the user. The data will not be transferred to third parties.

The following information is processed when the website is called up or when data is called up on this website: website, from which you visit us, the sub-pages you visit on our website, date and time, the name of your Internet browser used and your IP address. This data is evaluated anonymously and is used for statistical purposes only.

Cookies

Our website uses so-called cookies. These are small text files that are stored on your mobile device using the browser. They’re not doing any damage.

We use cookies to make our website user-friendly. Some cookies remain stored on your device until you delete them. They enable us to recognize your browser the next time you visit us. If you do not wish this, you can set your browser so that it informs you about the setting of cookies and you only allow this in individual cases. When cookies are deactivated, the functionality of our website may be limited.

Web analysis

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site, to constantly improve our website and adapt it to users’ needs. The following data is collected and recorded when you use the website:

  • Page views
  • Usage behavior (duration of use, clicks, scrolling speed…)
  • Approximate location data
  • From which website your visit to our website was started
  • Information about the web browser used, terminal device used, internet provider
  • IP address in shortened form (no unique identification possible)

The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. We expressly point out that the USA is not certified to have the same level of data protection as the EU. However, if IP anonymisation is activated on this website, Google will reduce your IP address within Member States of the European Union or in other states party to the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website and Internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.

The cookies are stored in your web browser for a period of two years since your last visit, thus enabling recognition on future visits to our website by means of a randomly generated user ID. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of this website.

You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available under the following link (http://tools.google.com/dlpage/gaoptout?hl=en).

You can prevent the collection by Google Analytics by clicking on the following link. An opt-out cookie is set to prevent future collection of your data when you visit this website:

Disable Google Analytics

For more information on terms of use and data protection, please visit http://www.google.com/analytics/terms/de.html or https://www.google.de/intl/de/policies/. Please note that the code “anonymizeIp” has been added to Google Analytics on this website to ensure anonymous collection of IP addresses (so-called IP masking).

The collected user-related data is deleted automatically after 14 months.

The legal basis for the processing of your personal data is your consent pursuant to Article 6 subsection 1a GDPR and/or our legitimate interest in ensuring the error-free operation of this website and to make improvements to this website operation (Article 6 subsection 1 f GDPR).

 

Processing purpose “marketing“:
For the commercialization of our products we process the following personal data of contact persons at our customers: name, date of birth, contact date, firm, function, username, bank data, UID-number, social insurance number, tax-number, OAK-number. The legal reasons for the processing are the contractual relationship between the costumer and G.L. Pharma GmbH or consent of the data subject. Most of the processed data is sent to us by the customers themselves and some of the contact information is public. Provided that it is it is necessary for the fulfilment of the contract, the data will be transferred to contractors involved in the supply or service (e.g. shipping companies, etc.) and will also be transferred, if necessary, to the EU / EEA area as well as to third countries.

You can find a list of non-EU countries, which are certificated by the European Commission to have an adequacy of the protection of personal data, on the following website: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en

The legal basis for the processing of your personal data is your consent pursuant to Article 6 subsection 1 a GDPR, a possible contract performance pursuant to Article 6 subsection 1 b GDPR and/or our legitimate business interest pursuant to Article 6 subsection 1 f GDPR.

 

Processing purpose “business development, purchasing, registration and order processing“:
For the initiation and processing of business, purchasing, registration of pharmaceutical products and order processing we process the following personal data of contact persons at our suppliers, service-providers and customers: name, contact date, firm, title, function.

The legal reason for the processing is the preliminary contractual relationship as well as the contractual relationship with suppliers and customers. Provided that it is necessary for the fulfilment of the contract, the data will be transferred to banks for the purpose of the settlement of payment, to insurance companies, appropriate authorities as well as contractors involved in the supply or service (e.g. shipping companies, etc.) and will also be transferred, if necessary, to the whole EU / EEA area as well as to third countries.

You can find a list of non-EU countries, which are certificated by the European Commission to have an adequacy of the protection of personal data, on the following website: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en

The legal basis for the processing of your personal data is your consent pursuant to Article 6 subsection 1a GDPR and/or a possible contract performance pursuant to Article 6 subsection 1b GDPR and/or our legitimate business interest pursuant to Article 6 subsection 1f GDPR.

 

Processing purpose “job application“:
For the job application procedure and the storage of the application for future consideration (with the consent of the applicant) we process the following personal data of job applicants: name, date of birth, place of birth, gender, nationality, title, contact details, desired position, religious confession, social security number, education work experience, hobbies, details about family members, certificates, publications, marital status, basic military / civilian service, work permit, asylum application, driving license / forklift licence and written records of the job interview.

The legal reason for the processing is the preliminary contractual relationship between the applicant and G.L. Pharma GmbH.

The applicant data will be deleted after 6 months at the latest, unless the applicant has expressly consented that we may keep the application in evidence. The data of applicants will not be transferred to third parties.

 

Processing purpose “pharmacovigilance“:

We are required by law to maintain a pharmacovigilance system. The term pharmacovigilance covers the monitoring of medicinal products used for the prevention, diagnosis or treatment of diseases in the period following their marketing authorisation. Reports on adverse drug reactions (ADR) are recorded in a pharmacovigilance database without the name or contact data of the reporting person or patient.

In the course of ADR reporting we process the following personal data of the patient if communicated by the reporting person (e.g. patient, doctor, relative, etc.) and if they are necessary for processing the report: name and contact details, age, date of birth, gender, body height and body weight, medical history (including information on medication), state of health and details of any adverse drug reactions.

Reporter’s personal data is used for processing the report and for reasons of traceability, to obtain further information on the ADR, if necessary: name, contact details, medical qualification and relationship to the person concerned by the report.

Personal data processed for pharmacovigilance purposes are protected by technical and organisational measures. These include security measures that restrict access to personal data to those employees who need the data to perform legally required PV tasks. Physical, electronic and procedural measures are implemented to protect personal data from loss, destruction, damage and unauthorised access. Where necessary, personal data is processed in pseudonymised form.

For the proper processing of ADR reports, it may also be necessary for some data to be forwarded internally to other departments. Personal data are transferred to the European Medicines Agency (EMA); if necessary also to other health authorities and to the marketing authorisation holder/pharmacovigilance contractor (in the entire EU/EEA area as well as to third countries) due to legal obligations or for reasons of public interest in the area of public health.

A forwarding of ADR reports to third countries for which the European Commission has confirmed an adequate level of data protection is generally carried out in pseudonymised form without forwarding the contact data of the reporter/the person concerned. Exception: Forwarding of the reporter’s contact data is required to enable the contractual partner to obtain further information on the ADR. Contact data, without exception, is only forwarded to those third countries for which there is an adequacy decision by the European Commission.

A list of non-EU countries (third countries) that have been certified an adequate level of data protection by the European Commission can be found at: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.

A transfer to third countries for which the European Commission has not confirmed an adequate level of data protection is carried out in pseudonymised form without forwarding the contact details of the reporter or the concerned person without exception. In addition, further data protection-compliant adaptations are made before transmission to comply with the General Data Protection Regulation (GDPR).

The legal basis for the processing of personal data is the GDPR, Article 6 and Article 49 subsection d).

 

Processing purpose “medical inquiries”
Within the scope of medical inquiries, information on products approved by us is given to patients, doctors, pharmacists, etc. and pharmacovigilance relevant information is passed on to our pharmacovigilance department. In the course of medical inquiries, the following data will be processed: Date of receipt, position of the inquirer (e.g. doctor, pharmacy, patient, hospital), product, subject of the inquiry, answer (with date and reference), PV-relevance, responsible PV-employee as well as the name of the person providing information. If you submit sensitive data about your health, religion or sex life in the course of an inquiry in writing, such information will only be processed if it is relevant and necessary for answering the inquiry.

The basis for processing is the legally prescribed guarantee of high quality and safety standards in health care, pharmaceuticals and medical products. It will not be passed on to third parties. If the request is a pharmacovigilance-related topic, the explanations on the “processing purpose pharmacovigilance” apply.

The legal bases for the processing of your personal data are your consent pursuant to Article 6 subsection 1 a GDPR or the fulfillment of a legal obligation pursuant to Article 6 subsection 1 c GDPR, the protection of your vital interests pursuant to Article 6 subsection 1 d GDPR and/or our legitimate business interest pursuant to Article 6 subsection 1 f GDPR.

How long will the personal data be stored?

Personal data will only be stored for as long as it is necessary to fulfil a contractual relationship or a legal obligation. After this period, the personal data will be anonymized or deleted.

Which rights do you have as a data subject?

According to current data protection law, you can request the following from the person in charge:
• Right of access by the data subject (Art 15 GDPR)
• Right to rectification and right to erasure (Art 16 and 17 GDPR)
• Right to restriction of processing (Art 18 GDPR)
• Right to data portability (Art 20 GDPR)

You also have the right,
• to revoke your consent upon processing your personal data (Art 13 sec 1 (c) and Art 14 sec 2 (d) GDPR)
• to object the processing of the personal data (Art 21 GDPR)
• to lodge a complaint with a supervisory authority (Art 13 sec 2 (d) and Art 14 sec 2 (e) GDPR

Who is responsible for processing my data in accordance with this Privacy Policy?

G.L. Pharma GmbH
Schlossplatz 1
8502 Lannach
Austria

If you have any further questions or comments regarding the processing of your personal data or the exercise of your rights regarding data protection, please contact us at dataprivacy@gl-pharma.at.