Privacy policy - PromoFarma.com

Privacy Policy

Basic information on data protection

Data processing controller

PromoFarma Ecom, S.L.

Av. Diagonal 534, 6º, 08006, Barcelona, Spain

Main purposes of the processing
  • To manage your registration as a user of the platforms.
  • To manage purchases of products and/or services.
  • To send marketing communications.
  • To resolve queries sent through the blog.
Main legitimate basis for processing
  • To execute purchase contracts.
  • Consent.
  • Legitimate interest.
  • Compliance with legal obligations.
Main recipients
  • Pharmacies.
  • Banks and banking institutions.
  • Law enforcement agencies and forces.
  • Service providers.

International data transfer is envisaged.

Rights

Among others, the rights of access, rectification, deletion, opposition and data portability, and the right to oppose the processing and at any time for reasons related to your particular situation, in the event that the processing is based on legitimate interest.

Source
  • Provided by the user.
  • Obtained in relation to browsing behaviour.
Who is in charge of the personal data processing?
  • Controller: PromoFarma Ecom, S.L.
  • Registered address: Av. Diagonal 534, 6º, 08006, Barcelona, Spain
  • Corporate Tax ID No.: B65130122
  • Public Register: Registered in the Mercantile Registry of Barcelona, in Volume 40.021, Folio 13, Section 8, Sheet number B-310.366, Entry 1

Data protection officer (hereinafter, “DPO”):

  • Contact details of the DPO: DPO Committee
  • Telephone: +34 902 930 918
  • E-mail: legal@promofarma.com
  • Website: www.promofarma.com

You may contact us by e-mail at legal@promofarma.com or by calling the telephone number +34 902 930 918 from Monday to Friday, 8 a.m. to 8 p.m.

The cost of calls is 15 cents for the call connection and 7.2 cents/min. from landlines. To find out the rate from your mobile, check with your operator.

Why do we process your data?

PromoFarma processes user data both manually and automatically for the following specific purposes:

  • To manage your user registration on the online platforms owned by PromoFarma Ecom, S.L. (www.promofarma.com or another domain landing page). However, in all cases you must verify and validate your registration on each of the platforms by entering your username and password in the consent form.
  • To manage the purchases of products and/or services you make over the Website, as well as the related invoicing and shipping.
  • To respond to queries and issues raised on the blog www.promofarma.com/blog, via the “Pharmaceutical queries” section.
  • To send regular communications (via e-mail, post and/or SMS) with offers, promotions and news related to our online platforms, unless the user indicates they do not wish to receive these or opposes or withdraws their consent.
  • To send regular marketing and/or advertising information related to pharmaceutical, OTC, beauty, personal care and child health care products, as well as professional value-added services for end users and for professional users within the pharmaceutical market, unless the user indicates they do not wish to receive these or opposes or withdraws their consent.
  • To compile anonymous statistical reports regarding the access and behaviour of the Website’s users.
  • To create user profiles, to be able to carry out targeted marketing based on data related to previous purchases (browsing data, access habits, traffic), unless the user opposes or withdraws their consent.
  • To comply with the relevant legal obligations.
What types of data do we process?

PROMOFARMA processes the following types of data:

  • Identification data: name, surname, postal address, e-mail address, postcode, telephone number, town/city, etc.
  • Personal details: date of birth, gender, etc.
  • Health data: illnesses, conditions, etc.
  • Traffic and location data.
  • Electronic communications metadata.
  • Sales data.
  • Financial or economic data.

The fields marked with an asterisk (*) on the forms on PromoFarma’s online platforms are required to fulfil the established contractual or legal purposes.

Therefore, if the user does not provide these data, it will not be possible to register them on the website or process their requests.

If the user provides the details of any third party, it is understood that the user has obtained the consent of the latter and undertakes to inform them of the information contained in this clause, releasing PromoFarma of any liability in this regard. However, PromoFarma may carry out the necessary checks to confirm this, adopting the corresponding due diligence measures, in accordance with data protection regulations.

What is our legitimate basis for processing your personal data?

The legitimate basis on which PromoFarma processes user data is user registration on the different websites specified in the user consent form that is requested in each case.

Meanwhile, the legitimate basis for processing purchases of products or services made over the Websites, and the corresponding billing and shipping, is the execution of the contract.

The processing of data provided through the “Pharmaceutical queries” section is based on the legitimate interest of resolving the queries raised by users.

The processing of data for the purpose of sending electronic newsletters with offers, promotions and news related to our online platforms, marketing and/or advertising information, the compilation of anonymous statistical reports on the access and behavioural habits of website users and the creation of customer profiles using data related to the products and services purchased from PromoFarma are based on the company’s legitimate interest in carrying out said activities in accordance with current legislation.

The different consents obtained for the above-mentioned purposes are independent of each other and the user may therefore withdraw one or several of their consents without this affecting the others.

Furthermore, the user’s information may be used to comply with the different legal obligations of PromoFarma.

Who are the recipients of the data?

Your personal data may be communicated by PromoFarma to:

  • Pharmacies, OTC pharmacies and professionals in the health and beauty sector, for the sole purpose of allowing said parties to issue the corresponding invoice and manage the collection or, where applicable, delivery of the order to the address indicated by the user.
  • State law enforcement agencies and forces, by virtue of that which is established by law.
  • Banks and banking institutions, to receive payment for the services offered.
  • Service providers who manage the data processing described in the privacy policy, in accordance with current data protection regulations. Said service providers shall not process your data for their own purposes of which PromoFarma has not been previously informed.
Will your data be transferred internationally?

Your personal data may be sent to recipients located in countries outside the European Economic Area, including countries that do not ensure a similar level of data protection to the EU. However, in such cases, the data will be handled in strict compliance with European and Spanish legislation, as well as in accordance with the following guarantees:

Recipient category Country Guarantee
Technology Services Providers USA Privacy Shield
How long will we store your personal data?

Your data will be stored for as long as needed to fulfil the purposes for which they were collected, unless you request to cancel your registration with PromoFarma, or you oppose or withdraw your consent. However, this period may be extended if you give your express authorisation for this purpose or in the case of specific processing arising from the contractual relationship that must still be carried out after said period.

What rights do you have regarding the processing of your data?

As the owner of the data, you can write to us at PromoFarma, Av. Diagonal, 534, 6º, 08006, Barcelona or at the e-mail address legal@promofarma.com, attaching a photocopy of the document that proves your identity, to exercise the following rights at any time and free of charge:

  • To withdraw your consent.
  • To obtain confirmation regarding whether or not PromoFarma is processing your personal data.
  • To access your personal data.
  • To rectify imprecise or incomplete data.
  • To request the deletion of your data if they are no longer required for the purposes under which they were collected, among other reasons.
  • To request that PromoFarma restrict the processing of your data when any of the conditions envisaged in the data protection regulations are met.
  • In certain circumstances, and for reasons related to the particular situation of the user regarding the processing of their data, the user may oppose said processing. PromoFarma shall stop processing the data except when there exist overriding legitimate reasons, or for the purpose of processing or defending against possible claims.
  • To obtain human intervention, to express your point of view and to contest the automatic decisions adopted by PromoFarma, where applicable.
  • To request the portability of your data.
  • To file a claim with the Spanish Data Protection Agency (www.agpd.es) if you consider that PromoFarma has infringed any of your rights as recognised under the applicable data protection legislation. Notwithstanding the above, the interested party may also contact the PromoFarma Data Protection Officer, whose details are as follows: DPO Committee; telephone: +34 902 930 918; e-mail: legal@promofarma.com.

Notwithstanding the foregoing, the interested party may also contact the PROMOFARMA Data Protection Officer by writing to C/ Diagonal 534, 6º, 08006, Barcelona, Spain, or to the e-mail address clientes@promofarma.com, in all cases attaching proof of identity and specifying the right or rights that they wish to exercise under the terms established by current regulations.

Where does the data come from when they are not provided by their owner?

Together with the information you provide us with directly (for example via forms, etc.), we also obtain information on your browsing habits, if you consent to this.

If data is provided which refers to physical persons other than the person providing the data, the latter states that they have informed and obtained the prior consent of said persons for the processing of their data for the purposes envisaged in these clauses. In the specific case of minors, if the person providing the data is not the minor’s legal guardian, they undertake to obtain the express consent of the latter.

What security measures do we use to protect your data?

PromoFarma will process your data with the strictest confidentiality at all times, while maintaining the mandatory duty to secrecy over the same, pursuant to the provisions of the applicable regulations, adopting for this purpose the technical and organisational measures needed to guarantee the security of your data and avoid their alteration, loss, unauthorised processing or access, taking into account the state of the technology, the nature of the data stored and the risks to which the data are exposed.

Changes to the Privacy Policy

PromoFarma reserves the right to modify this Privacy Policy to adapt it to any relevant legislative changes. In such cases, notification will be given on the Website of the changes to be introduced with reasonable notice before their implementation.

Last updated: 11 May 2018

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