Clinigen Clinical Supplies Management Group respects your privacy and is committed to protecting your personal data. This privacy policy will tell you about how we look after your personal data when you visit our websites and tell you about your privacy rights and how the law protects you.
This privacy policy aims to give you information on how Clinigen Clinical Supplies Management Group collects and processes your personal data through your use of its website, including any data you may provide through this site when you sign up to our newsletters, or submit any information.
This website is not intended for children and we do not knowingly collect data relating to children, unless we have agreed this with you.
It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.
This privacy policy is issued on behalf of Clinigen Clinical Supplies Management Group so when we mention ”Clinigen Clinical Supplies Management”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in Clinigen Clinical Supplies Management Group responsible for processing your data. Clinigen Clinical Supplies Management Inc. is the controller and is responsible for the processing of personal data through this website. Clinigen Clinical Supplies Management Inc. appointed Clinigen Clinical Supplies Management SA as its EU representative.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below:
Clinigen Clinical Supplies Management Inc.
Data Protection Officer : privacy@clinigencsm.com
You have the right to make a complaint at any time to the Data Protection Authority, the Belgian supervisory authority for data protection (www.privacycommission.be). We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Authority so please contact us in the first instance.
Personal data means any data about an individual from which that person can be identified. It does not include data where the identifiers has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We may also collect, use and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy policy.
Unless we have told you elsewhere in this policy or otherwise in writing, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) through our websites. Nor do we collect any information about criminal convictions and offences through our websites.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. We have described below how we plan to use your personal data, and which of the legal bases we rely on to do so.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
|
Type of data
|
Lawful basis for processing including basis of legitimate interest |
To register you as a new prospect
|
(a) Identity (b) Contact |
Performance of a contract with you
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To enable you to partake in a prize draw, competition or complete a survey
|
(a) Identity (b) Contact (c) Profile (d) Usage |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|
(a) Identity (b) Contact (c) Technical
|
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant website content to you and measure or understand the effectiveness of the advertising we serve to you
|
(a) Identity (b) Contact (c) Profile (d) Usage (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our strategy) |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
|
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our m strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you where you have consented to receive such information
|
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) Consent |
Where we talk about ‘Legitimate Interest’ we mean the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will not send you unsolicited marketing information without your consent, and we will get your express opt-in consent before we share your personal data with any company outside Clinigen Clinical Supplies Management Group of companies for marketing purposes.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via letter, email or text message, or where we are processing your sensitive personal data.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us that we are required to retain as a result of any service purchase or other transactions.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may share your personal data within Clinigen Clinical Supplies Management Group. This will involve transferring your data outside the European Economic Area (EEA).
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.
Many of our external third parties are based outside the European Economic Area (EEA), and as a result their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click the links below to find out more about these rights:
If you wish to access your own personal data or if you wish to exercise any of the other rights set out above, please contact the Data Protection Officer privacy@clinigencsm.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you have any questions regarding this Policy or any related issue, you should contact privacy@clinigencsm.com
Last updated: 11-01-2021