Privacy Policy

Basic information on data protection

This privacy policy has been drafted with the aim of complying with the duty of transparency in the processing of personal data that PromoFarma Ecom S.L. (hereinafter "PromoFarma") and Helena Abreu Unipessoal, Lda. (hereinafter “Farmacia Central") may carry out as independent data controllers, or as joint controllers, in accordance with the provisions of 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 (General Data Protection Regulation). Below is the information on the data processing carried out on the website [www.promofarma.com](https://www.promofarma.com), in an executive and summarized form:

Data controller	PromoFarma	Joint controllership: PromoFarma and Farmacia Central	Farmacia Central
Main purposes of processing	Acts as an independent data controller in the management of orders for parapharmaceutical, cosmetic and hygiene products that it sells on the Portal: Management of orders to PromoFarma Management of PromoFarma customer service Commercial prospecting by PromoFarma Management of legal proceedings and compliance	They act as joint controllers in the field of administrative and operational management of the Portal: Creation and management of the account on the Portal Service quality management Management of referral/loyalty programs Web statistics Improvement of the Portal Personalization of your experience in Explora	Acts as an independent data controller in the management of orders for pharmaceutical, parapharmaceutical, cosmetic and hygiene products that it sells on the Portal: Management of orders to Farmacia Central Management of Farmacia Central customer service Commercial prospecting by Farmacia Central Management of legal proceedings and compliance
Main legal bases	Consent Performance of the contract Legitimate interest Compliance with legal obligations	Performance of the contract Legitimate interest Consent Compliance with legal obligations	Consent Performance of the contract Legitimate interest Compliance with legal obligations
Main recipients	PromoFarma and Farmacia Central, as well as their authorized personnel Companies of the Group to which PromoFarma belongs Companies of the Group to which Farmacia Central belongs Payment service providers of PromoFarma and Farmacia Central Delivery service providers of PromoFarma and Farmacia Central Other subcontractors of PromoFarma and Farmacia Central (data hosting service providers, IT services, etc.). Administrative and judicial authorities.
Rights over your personal data	Among others, the right of access, rectification, erasure, objection and data portability, the right to object to the processing at any time, on grounds relating to your particular situation, in the event that the processing is based on legitimate interest, as well as to withdraw your consent at the emails indicated below. If necessary, you also have the right to lodge a complaint with the AEPD ([www.aepd.es](https://www.aepd.es)).
	legal@promofarma.com	legal@promofarma.com	farmaciacentral@promofarma.com
Origin of the personal data collected	Data provided directly by you on the Portal or as part of your interactions with PromoFarma and/or Farmacia Central Data collected automatically through cookies and other trackers used on the Portal

Additional information on the protection of your personal data

The website [www.promofarma.com](https://www.promofarma.com) and the application (hereinafter, collectively the “Portal”) are controlled by PromoFarma Ecom S.L. (hereinafter "PromoFarma”) and Helena Abreu Unipessoal, Lda. (hereinafter “Farmacia Central”). The purpose of the Portal is the online sale of pharmaceutical, parapharmaceutical, cosmetic and hygiene products.

To access, consult, browse and use the Portal and its services, it is necessary for you to provide your personal data to PromoFarma and Farmacia Central. In the section “For what purposes do we process your data and on what legal basis?” you will find those processing activities that will be carried out by Farmacia Central and PromoFarma, either jointly or individually, as data controllers.

EXPLORA. Within the application you will find the “Explora” section, which includes information about products and services offered in the application. Additionally, it offers users the possibility to personalize Explora posts and send you communications tailored to your interests, based on your activity. This functionality involves carrying out user profiling. As indicated in the section "For what purposes do we process your data and on what legal basis?", the legal basis that enables this processing is consent, given by the user within the application environment. In any case, you may withdraw your consent at any time. However, by doing so, you will not be able to access personalized content and may lose some functionalities of Explora. For more information on the exercise of rights, you can review the section "What rights do you have over your personal data?"

We ask that you read and familiarize yourself with this policy, which explains how PromoFarma and Farmacia Central use your personal data and how you can exercise your rights in this regard. This policy complements the Terms of Use (“TOU”) and the General Terms and Conditions (“GTC”) of PromoFarma.com (https://www.promofarma.com/es/legal/contract), as well as any document or information notice that refers to this policy.

For any questions and to exercise your rights, you can contact directly

PromoFarma by sending an email to legal@promofarma.com; and/or
Farmacia Central by sending an email to farmaciacentral@promofarma.com.

Who is the controller of the personal data?

Promofarma Ecom, S.L.

Registered office: Av. Diagonal 534, 6º, 08006, Barcelona, Spain
CIF: B65130122
Public Registry: Registered in the Commercial Registry of Barcelona; in volume 40,021, sheet 13, section 8, page number B-310,366, entry 1

Farmácia Central (Helena Abreu, Unipessoal Lda.)

Registered office: MONTEMOR-O-NOVO, Rua 5 de Outubro, 69
NIF: 514910224
Public Registry: Recorded in the permanent certificate of the commercial registry under Av.1 AP. 150/20190417

PromoFarma and Farmacia Central act as joint controllers in the field of administrative and operational management of the Portal.
PromoFarma acts as an independent data controller in the management of orders for parapharmaceutical, cosmetic and hygiene products that it sells on the Portal.
Farmacia Central acts as an independent data controller in the management of orders for pharmaceutical, parapharmaceutical, cosmetic and hygiene products that it sells on the Portal.

For what purposes do we process your data and on what legal basis?

When PromoFarma acts as data controller, we process your personal data for the following reasons:

Purposes	Use of your data	Legal basis
Management of orders to PromoFarma	process your order, the purchase made and the delivery to be carried out manage your invoices and payments ensure the follow-up of the commercial relationship	Performance of the GTC applicable to your order
Management of PromoFarma customer service	handle your requests (inquiries, complaints, claims, etc.) to respond to you, if necessary refund your money or send you a new product in case of return, if applicable respond to your order requests through the Virtual Assistant, including: (a) processing your conversation history (free-text inputs and generated responses); (b) if your conversation is forwarded to customer service, using your email address to contact you again; (c) your IP address, log files, location information and other data.	Performance of the GTC applicable to your order
Commercial prospecting aimed at PromoFarma customers	the identification and contact data will be processed to send you commercial communications similar or analogous to those already contracted on the Portal as long as the user does not object	Legitimate interest of PromoFarma legally enabled under the information society services regulations
Commercial prospecting aimed at potential customers of PromoFarma	the identification and contact data will be processed to send you commercial communications about the Portal and the products sold on it	Your consent
Resolution of disputes and incidents and management of pre-litigation or litigation proceedings	the data related to your status as a customer may be processed to: (i) manage any breach of the TOU and GTC or any other identified breach; and (ii) manage any dispute or litigation	Legitimate interest of PromoFarma in defending their respective rights and interests
Compliance with legal and regulatory obligations	compliance with legal and regulatory obligations respond to your requests to exercise your rights	Legal and regulatory obligations to which PromoFarma is subject

When PromoFarma and Farmacia Central act as joint controllers, we process your personal data for the following reasons:

Purposes	Use of your data	Legal basis
Creation and management of your account on the Portal	check whether you meet all the conditions necessary to create your account create your account allow you to log in to the Portal allow you to track your current order and access your history of previous orders allow you to update your account check the security of your account	Performance of the TOU and GTC applicable to your order The legitimate interest of PromoFarma in safeguarding the security of your account
Service quality management	the identification, contact and contribution-related data will be processed to: (i) collect, take into account and, where appropriate, publish your rating/opinion on the products ordered; and (ii) carry out satisfaction surveys (opinion requests, polls, etc.), all in order to evaluate and improve the Portal and the services offered	Legitimate interest of PromoFarma and Farmacia Central in knowing the quality of the service provided and customers' opinions
Management of referral/loyalty programs	allow the User to participate in the referral program and benefit from discounts on their orders, if applicable	Performance of the GTC applicable to your order
	the identification, contact and referral-program participation data will be processed to send you referral emails, inviting you to register on the Portal and thus benefit from discounts on your orders, if applicable	These activities will only be carried out when the User who sends the referral states that they have the express consent of the recipient.
Personalization of web browsing and statistics	the connection and browsing data will be processed to: produce aggregated data reports for statistical and analytical purposes by the Controller, as reflected in the Cookies Policy; (ii) compile statistics on the use of the Portal; and (iii) facilitate your browsing on the Portal	Your consent
Personalization of your experience in Explora	the browsing and behavioral data, such as visits, likes on posts or follows made by the user in the Explora section within the Portal.	Your consent given in the application
Management of the improvement of the Portal	the data you send us through contacts made will be processed to: (i) ensure the security of the Portal; and (ii) manage the maintenance, support and development of the Portal	Legitimate interest of PromoFarma and Farmacia Central in the improvement of the Portal

When Farmacia Central acts as data controller, we process your personal data for the following reasons:

Purposes	Use of your data	Legal basis
Management of orders to Farmacia Central	process your order and deliver it manage your invoices and payments ensure the follow-up of the commercial relationship	Performance of the GTC applicable to your order If it includes health data: Legitimate interest of Farmacia Central (art. 9(2)(h) GDPR)
Management of Farmacia Central customer service	handle your requests (inquiries, complaints, claims, etc.) to respond to you, if necessary refund your money or send you a new product in case of return, if applicable respond to your order requests through the Virtual Assistant, including: (a) processing your conversation history (free-text inputs and generated responses); (b) if your conversation is forwarded to customer service, using your email address to contact you again; (c) your IP address, log files, location information and other data.	Performance of the GTC applicable to your order If it includes health data: Legitimate interest of Farmacia Central (art. 9(2)(h) GDPR)
Commercial prospecting aimed at Farmacia Central customers	the identification and contact data will be processed to send you commercial communications similar or analogous to those already contracted on the Portal as long as the user does not object	Legitimate interest of Farmacia Central legally enabled under the information society services regulations If it includes health data: Legitimate interest of Farmacia Central (art. 9(2)(h) GDPR)
Commercial prospecting aimed at potential customers of Farmacia Central	the identification and contact data will be processed to send you commercial communications about the Portal and the products sold on it	Your consent
Resolution of disputes and incidents and management of pre-litigation or litigation proceedings	the data related to your status as a customer may be processed to: (i) manage any breach of the TOU and GTC or any other identified breach; and (ii) manage any dispute or litigation	Legitimate interest of Farmacia Central in defending their respective rights and interests
Compliance with legal and regulatory obligations	compliance with legal and regulatory obligations respond to your requests to exercise your rights	Legal and regulatory obligations to which Farmacia Central is subject If it includes health data: Legitimate interest of Farmacia Central (art. 9(2)(h) GDPR)

What categories of personal data concerning you are collected and used?

All the data you enter on the Portal or when you communicate with PromoFarma and Farmacia Central, specifically the following:

Categories of data	Specific data
Identification data	Surname, first name, date of birth, customer number
Contact data	Email address, postal address, telephone number
Banking and financial data	Payment method, billing address
Data relating to your order	Order number, date and time of the order, order status, products ordered, order value, gift voucher used, discounts granted, delivery address and method
Data relating to order returns	Date and time of the return request, ordered products returned, reasons for the return, amount refunded
Data relating to the commercial relationship	Order history, order frequency, requests (inquiries, complaints, claims, etc.), interactions with PromoFarma and/or Farmacia Central services depending on the products ordered
Data relating to your contributions to the Portal	Ratings/reviews of the products ordered and your experience as a customer/user
Data relating to your participation in referral programs	Email address of the referred person, gift certificate issued, if applicable
Browsing and behavior data in Explora	Visits, likes on posts or follows, among others, made by the user in Explora
Health data (processed only by Farmacia Central)	Potential details of the pharmaceutical consultation between the User and Farmacia Central. Likewise, when the customer purchases non-prescription medicines from Farmacia Central, identification data, contact data and data relating to their order in that transaction will be processed by Farmacia Central as Health data.

In addition, certain data is collected automatically through cookies and other trackers used on the Portal, namely:

Categories of data

Specific data

Purposes

Connection and browsing data

Date and time of connection, IP address, geolocation, device, browser, operating system, system configuration data, pages viewed

This data is necessary for the correct technical functioning of the Portal and its services, as well as for statistical purposes. For more information, see the Cookies Management Policy: https://www.promofarma.com/es/legal/cookies

Geolocation data helps protect the security of your account.

Some of this data is mandatory and some optional in order to use all the services offered by the Portal, especially to place an order on the Portal. The mandatory or optional nature of the personal data to be provided is indicated on the collection forms. If you refuse to provide the requested mandatory data, PromoFarma and Farmacia Central will not be able to process your request (such as your request to create an account, your order, your contact request, etc.).

Where applicable, you may be asked to provide the personal data of a third party, in particular when you place an order for someone close to you or participate in the referral program. In this context, we emphasize that you must obtain their prior authorization, inform these persons of the communication and processing of their personal data by PromoFarma and Farmacia Central, and provide them with this policy.

Who are the recipients of your data?

Your personal data may be communicated to the following categories of recipients:

Recipients	Purposes
PromoFarma and Farmacia Central, as well as their authorized personnel	Purposes of managing the Portal and its services
Companies of the Group to which PromoFarma belongs	Exclusively administrative, operational or commercial purposes
Companies of the Group to which Farmacia Central belongs	Exclusively administrative, operational or commercial purposes
Payment service providers of PromoFarma and Farmacia Central	To make the payment and store your bank card/PayPal account only if you have given your consent
Delivery service providers of PromoFarma and Farmacia Central	Only for delivery purposes
Other subcontractors of PromoFarma and Farmacia Central (data hosting service providers, IT services, etc.)	Exclusively technical or logistical purposes
Administrative or judicial authorities	Only at their express and reasoned request or in the event of a proven breach of legal or regulatory provisions
External consultants	Only in the context of managing possible litigation and other legal matters, if necessary
Virtual assistant	The provider of our virtual assistant is Zowie, Inc., located at 8 The Green, Dover, DE 19901, USA. Zowie, Inc. processes your personal data on our behalf as a processor and is certified under the U.S. Data Privacy Framework (DPF). We operate the virtual assistant in a private cloud environment located in the European Union.
Other third parties	After or during the restructuring, reconstitution, acquisition, loan financing, merger, sale of assets of PromoFarma and/or Farmacia Central or a similar transaction, as well as in the event of insolvency or judicial sale in which the personal data is transferred to one or more third parties as assets of PromoFarma and/or Farmacia Central

Virtual assistant

We use a virtual assistant so that you can receive automatically generated responses and support with your questions and other inputs at any time. We analyze your inputs to provide appropriate responses. The virtual assistant can provide you with general information about the status of your orders using the tracking number, without you having to log in to your user account.

If you use the chat window, we will retain your IP address for 30 days, in addition to the messages exchanged. Both are used to check and improve the response behavior of our virtual assistant. The data you enter when communicating will remain in our possession or that of the operator until you ask us to delete it, you revoke your consent for storage, or the purpose for which it is stored no longer applies (for example, after your request has been processed).

Our fully automated virtual assistant is available at any time to provide AI-assisted answers to your questions. The virtual assistant can answer questions about the platform and the services offered and, if you have the tracking number, inform you of the status of your orders. The virtual assistant does not offer any medical or pharmaceutical advice. For this reason, we ask that you do not ask questions related to your individual health. You can end a conversation with the virtual assistant at any time and request that your request be handled by a customer service representative

Will international transfers of your personal data be carried out?

As far as possible, your personal data is processed within the European Economic Area (EEA). In the event that the receiving country does not guarantee a level of protection of personal data equivalent to that of the EEA, PromoFarma and Farmacia Central respectively undertake, in the absence of an adequacy decision and after having carried out an assessment of the level of protection of your rights in the territory of the third State in which the recipient of your personal data is established, to adopt all necessary measures to ensure the protection of your personal data on the basis of appropriate safeguards (in particular, the standard contractual clauses in force).

Currently, PromoFarma and Farmacia Central only carry out international transfers to the United States due to the involvement of the providers and subcontractors with whom they have signed a data processing agreement involved in the provision of the services described in this privacy policy, with such transfers being covered by the standard contractual clauses under Regulation (EU) 2016/679 of the European Parliament and of the Council, amended on 4 June 2021.

You can obtain more information about this by contacting:

PromoFarma by sending an email to legal@promofarma.com; and/or
Farmacia Central by sending an email to farmaciacentral@promofarma.com

For how long will we keep your personal data?

In general, your personal data will be kept only for the period necessary to achieve the purposes for which it was collected or to comply with legal or regulatory requirements (applicable retention obligations/time limits).

With the following exceptions

the personal data associated with your account on the Portal (including data relating to your orders) is kept until you cancel your account on the Portal or your account has been inactive for three (3) years;
the data collected in connection with your requests (contact request, product return request, claim, etc.) is kept until they are fully processed;
the data collected in the course of your registration to receive commercial communications is kept until you unsubscribe;
The connection and browsing data is stored for 13 (thirteen) months.

Beyond these periods, your data is kept for:

3 (three) years from the cancellation/inactivity of your account for data kept for commercial prospecting purposes;
5 (five) years from the cancellation/inactivity of your account for data kept for evidentiary purposes;
2 (two) years in the case of data provided by the user in the context of the pharmaceutical care provided by Farmacia Central;
2 (two) years in relation to the data incorporated into the register of medicine orders by Farmacia Central; and
6 (six) years from the end of the accounting year in question for data stored for accounting purposes, as well as for commercial documents (invoices, order forms, delivery notes, commercial correspondence, etc.).

Once the contractual relationship has ended or erasure has been requested, the data may be kept (blocked), as a general rule, for the following five (5) years or for the limitation period for actions relating to possible legal or contractual liabilities, when this period is longer than the one mentioned above.

What rights do you have over your personal data?

In accordance with personal data protection legislation, you have the following rights over your personal data:

right of access to your personal data, allowing you to obtain clear, transparent and understandable information about how PromoFarma and Farmacia Central use your personal data and about your rights (as provided in this policy), as well as a copy of your personal data.
right of rectification of your personal data, allowing you to have your personal data modified if it is outdated, inaccurate or incomplete.
right to object to the processing of your personal data when it is based on the legitimate interests of PromoFarma and/or Farmacia Central. Therefore, PromoFarma and/or Farmacia Central will cease processing, unless there are compelling legitimate grounds that override your interests, rights and freedoms, such as compliance with a legal obligation (such as those imposed by the retention of certain documents containing personal data) or the establishment, exercise or defense of a right in legal proceedings. Specifically, you may exercise your right to object with respect to the processing of “Service quality management of Farmacia Central”, “Commercial prospecting aimed at Farmacia Central customers”, “Management of the improvement of the Portal”, “Service quality management of PromoFarma” and “Resolution of disputes and incidents and management of pre-litigation or litigation proceedings”.
right to the restriction of the processing of your personal data on a temporary basis, in particular to carry out checks, namely

when you contest the accuracy of your personal data, until PromoFarma and/or Farmacia Central can verify that it is correct;
if the processing is unlawful and, instead of requesting its erasure, you prefer to restrict its use;
if PromoFarma and/or Farmacia Central no longer need to process your data, but it is still necessary to allow you to assert, exercise or defend a right in legal proceedings;
if you object to the processing, in the exercise of your right to object, during the verification period intended to confirm that the legitimate interests pursued by PromoFarma and/or Farmacia Central override yours.

right to withdraw your consent at any time for the purposes for which it was collected. Specifically, you may withdraw the consents given with respect to the processing of “Commercial prospecting aimed at potential customers of Farmacia Central”, “Management of referral/loyalty programs”, “Personalization of web browsing and statistics” and “Personalization of your experience in Explora” without any need for justification. The withdrawal will not affect the lawfulness of the processing carried out previously. In the case of Explora, after withdrawal, you will not be able to access personalized content and may lose some functionalities of Explora.
the right to portability of your personal data, allowing you to receive the personal data provided, in a structured, commonly used and machine-readable format, and to transmit it to third parties, where technically possible. This right is not exercised in all circumstances and only applies if you meet all of the following conditions:

it refers only to your personal data, excluding any anonymous or third-party data;
it does not infringe the rights and freedoms of third parties, in particular those of PromoFarma and/or Farmacia Central (in particular trade secrets or industrial and intellectual property rights);
it refers to personal data processed by automated means (therefore, paper files are not covered);
the processing is based on your consent or on the performance of a contract entered into with PromoFarma and/or Farmacia Central.

right to erasure of your personal data (or right to be forgotten) when one of the following grounds applies

you object to the processing of your personal data and there is no compelling legitimate ground to continue such processing (such as the obligations that require the retention of certain documents containing personal data);
you object to commercial prospecting operations;
you decide to withdraw your consent on which the processing is based;
when your personal data is no longer useful for the initial purposes for which it was collected or another type of processing; the use made of your data does not comply with the applicable legal or regulatory provisions.

It is specified that the exercise of these rights depends on the legal basis of the processing, as indicated in the following table:

	Access	Rectification	Erasure	Restriction	Portability	Objection
Consent	Yes	Yes	Yes	Yes	Yes	Withdraw consent
Pre-contractual relationships			Yes		Yes	No
Contract			Yes		Yes	No
Legitimate interest			Yes		No	Yes
Legal obligations			No		No	No

In certain circumstances, PromoFarma and/or Farmacia Central may need to ask you for specific information to confirm your identity and ensure the exercise of your rights. This is another appropriate security measure to ensure that personal data is not disclosed to a person who does not have the right to receive it.

Depending on the personal data processing in question, to submit any query and exercise your rights, you can contact us directly:

PromoFarma by sending an email to legal@promofarma.com.; and/or
Farmacia Central by sending an email to farmaciacentral@promofarma.com.

The contact details of the data protection officer are

for PromoFarma: legal@promofarma.com
for Farmacia Central: farmaciacentral@promofarma.com.

Likewise, if you wish to request detailed information about the joint controllership agreement between PromoFarma and Farmacia Central, you can contact us at the following email address: legal@promofarma.com.

You can also lodge a complaint with the Spanish Data Protection Agency if you consider that the processing does not comply with current regulations (you can find more information at: https://www.aepd.es).

What is the source of the data when it has not been provided by the data subject?

In addition to the information you provide us directly (for example, through forms, etc.), we will obtain information about your browsing habits if you consent.

In the event that the data provided refers to natural persons other than the data subject, the data subject states that they have informed and obtained the prior consent of those persons for the processing of their data in accordance with the purposes set out in these clauses. In the specific case of minors, if the data subject is not the legal representative of the minor, they undertake to obtain the express consent of the latter.

What security measures do we implement to protect your data?

PromoFarma and Farmacia Central will process your personal data permanently with confidentiality and in compliance with the obligation of professional secrecy applicable to any healthcare professional, where applicable, in accordance with the provisions of the applicable regulations, adopting the appropriate contractual, technical and organizational measures for the protection of your personal data, specifically against possible breaches that may give rise, accidentally or unlawfully, to the destruction, loss, alteration, unauthorized access or disclosure of your personal data. These measures guarantee an adequate level of security of the personal data and take into account the state of the art, the costs of implementation in relation to the risks, and the nature of the data to be protected.

Likewise, PromoFarma and Farmacia Central will ensure that the members of their staff and all persons obliged to process the personal data concerning them comply with the established rules and procedures regarding personal data protection and, in particular, with the technical and organizational security measures implemented to protect your personal data. To the extent that the obligation of professional secrecy requires it, PromoFarma and Farmacia Central will ensure that the members of their staff and external service providers (data hosting service provider, IT service provider, etc.) are subject to a written confidentiality commitment, recalling the criminal consequences of failing to comply with these obligations.

Changes to the data protection policy

PromoFarma and Farmacia Central reserve the right to modify this personal data protection policy at any time to adapt it to any change in the Portal and its services or in the applicable regulations. The new updated personal data protection policy will be communicated to you in due course.

Last updated: 06/30/2026