Pharmacosmos UK (Pharmacosmos) is a limited company registered in England and Wales whose registered office is The White Building, 6th Floor, 33 Kings Road, Reading, RG1 3AR. We take our Data Protection obligations very seriously and this notice gives you information about our approach to Data Protection legislation (UK General Data Protection Regulation, Data Protection Act 2018, Privacy & Electronic Communications Regulations (PECR)) and provides you with information about how we manage your personal data.
For the purposes of this notice Pharmacosmos is the Data Controller. This means that we are responsible for deciding how we hold and use personal information about you. We are required under Data Protection Legislation to notify you of the information contained in this privacy notice.
This notice applies to our processing of personal data in respect of vendors, customers and partners. We may update this notice at any time, details of which are found at the end of this document. It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Please note our website and services are not intended for children and we do not knowingly collect data relating to children.
Pharmacosmos will collect and process your Personal Data for the purposes described below.
To carry out our professional collaboration with you:
Your professional contact information such as your name, email, phone number, title, and address may be stored in our databases. We will process such Personal Data for the purpose of negotiating and fulfilling our respective contractual obligations with the company you represent.
Our legal basis for such processing is the GDPR, article 6(1)(f) - legitimate interest. Our legitimate interest is to communicate with you as a representative of a company that we have contractual relations with.
Compliance with applicable pharma related law and regulations:
As a pharmaceutical company, we are in some cases legally required to process Personal Data. This applies in respect of supplier evaluation and handling of quality complaints.
For these purposes, we might process your Personal Data, such as your name & title, email address, phone number and address.
Our legal basis for such processing is the GDPR, article 6(1)(c) - compliance with a legal obligation.
Collaboration platforms
We provide partners access to data in various platforms, such as Partnernet and for this purpose we process name & title, email address, phone number, address and sometimes your picture.
Our legal basis for such processing is the GDPR article 6(1)(f) - legitimate interest. Our legitimate interest is to facilitate communication between ourselves and our partners, including the company you represent.
Financial transactions
We process your personal data such as name & title, email address, phone number, address and bank information to pay you, or your company, for a financial transaction with us.
Our legal basis for such processing is GDPR article 6(1)(b) - performance of a contract – in situations where we have a contractual relation with you individually, or GDPR article 6(1)(f) – legitimate interest - in situation where you are a representative of a company that we have a contractual relationship with.
Marketing events
If you participate in a Pharmacosmos event or conference, we process your personal data such as name & title, email address, phone number, specialisation, address, dietary requirements and travel itinerary.
Our legal basis for such processing is the GDPR, article 6(1)(f) - legitimate interest. Our legitimate interest is to facilitate and manage financial transactions with our vendors, customers and partners.
You sign up for our newsletter
We provide partners, affiliates, customers etc. with our newsletter and for this we process your name and email address.
Our legal basis for such processing is GDPR article 6(1)(a) – your consent, or article 6(1)(f) – legitimate interest. Our legitimate interest is to send you, as a representative of a company we collaborate with, information about our products and our business.
Screening for anti-bribery and sanctions
To comply with our legal obligations in relation to applicable national and international legislation to prevent bribery and sanctions violations, we may perform screening of the beneficial owners, managing directors and potentially other employees of our business partners, customers and vendors.
Our legal basis for such processing is the GDPR article 6(1)(c) – processing is necessary to comply with our legal obligations.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information 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 information without your knowledge or consent, however only where this in accordance with Data Protection legislation, is required for a proportionate reason or is strictly permitted by law.
We only share your information where we are strictly able to and only in accordance with Data Protection legislation. Your Personal Data will be treated as confidential information by those, who are allowed to process your Personal Data, and will only be used for the purposes set out herein. It will be stored by Pharmacosmos or a contracted third-party hosting provider.
We may transfer your Personal Data to our affiliated Pharmacosmos companies, or to third party service providers who deliver services to Pharmacosmos, or to relevant public authorities, if required by law. More information can be obtained by contacting our Data Protection Officer.
If your Personal Data is transferred to one of our affiliated companies or a third party located in a country outside the EU/EEA, Pharmacosmos will ensure that such transfer(s) will be carried out in accordance with the applicable data protection legislation, including the GDPR.
If your Personal Data is transferred to our affiliated companies outside the EU/EEA, without an adequacy decision, the transfer will be based on Pharmacosmos Intra-Group Agreements including the EU Commission’s Standard Contractual Clauses.
Transfers to third parties outside the EU/EEA, without an adequacy decision, will be safeguarded by ensuring that the third party enters into the EU Commission’s Standard Contractual Clauses and the UK ICO Addendum and the relevant assessments (TRA/TIA).
Should such requirements change, we will review the obligations and amend this notice as appropriate. More information can be obtained by contacting our Data Protection Officer.
Our retention schedule is in place to ensure your Personal Data is maintained only for as long as is necessary to achieve the respective purpose of the processing or to be able to comply with legal obligations (e.g. data retention requirements).
Personal Data collected for the purpose of complying with legal obligations in relation to applicable national and international legislation to prevent bribery and sanctions violations, will be retained for the duration of the contractual relationship plus 5 years. Further information regarding our retention periods can be obtained from our DPO.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Right to be informed by the provision of a privacy notice when your personal information is processed.
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.
Right to object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you.
Request the transfer of your personal information to another party.
Automated decision making we will not use automated decision-making technology, however, should this change we will update this notice appropriately.
If you want to exercise any of your rights, please contact our Data Protection Officer in writing.
We have put in place appropriate security measures to prevent your personal information from being accidently lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to our personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breaches and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have appointed a Data Protection Officer to oversee compliance with our Data Protection obligations. Our DPO can be contacted at info@pharmacosmos.co.uk or in writing to our registered office, The White Building, 6th Floor, 33 Kings Road, Reading, RG1 3AR.
If you have any questions about this privacy notice or how we handle your personal information, please contact our DPO. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for Data Protection legislation.
From time to time, we may revise this Privacy Notice. Any such changes will be reflected on this page. Pharmacosmos recommends that you review this Privacy Notice regularly for any updates. The date on which this notice was last revised is located below.
V.1.0 Initial creation 16/03/23 DPO
