1. General
A. Menarini Farmaceutica Internazionale SRL UK Branch ("We" or “us”) are committed to protecting and respecting your privacy.
This Privacy Policy applies to your use of:
In this Privacy Policy, the terms “personal data”, “processing”, “data controller” and “data processor” shall have the meaning ascribed to them in the General Data Protection Regulation ((EU) 2016/679, "GDPR").
This Privacy Policy sets out the basis on which any personal data We collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding personal data and how We will process it.
Our Site is not intended for individuals under 18 years of age. No one under the age of 18 may provide personal data to or through the Website. We do not knowingly collect personal data from minors under 18. If you are under 18, please do not create an account or send us any information about you.
Data Controller and Data Protection Officer:
The data controller is A. Menarini Farmaceutica Internazionale SRL (UK Branch) Menarini House, Mercury Park, Wycombe Lane, Wooburn Green, Buckinghamshire, HP10 0HH.
Tel: 01628 856 400
Incorporated in Italy with Limited Liability
Branch registered in England No BR016024
The Data Protection Officer (“DPO”) can be contacted at the following address: [email protected]
2. Personal data we may collect from you
We may collect and process ordinary personal data which you may provide when interacting with website functions, including browser data or requests to use services offered on the Website (here after, browsing data), as well as data collected by cookies as specified in the Cookie Policy.
Browsing data are data whose transmission to the Website is necessary for the functioning of the computers which operate the Website and of the Internet communication protocols. This category includes, for example, IP addresses or computer domain used to visit the Website and other parameters pertaining to the operating system used to connect to the Website. The Company collects these and other data (such as, for example, number of visits and time spent on the Website) merely for statistical purposes and in anonymous form in order to monitor the functioning of the Website and improve its performance. Such data is not collected to be associated with other information regarding, or for the identification of, users; however, such information, by its very nature, may enable the Company to identify users through processing and association with data held by third parties. Browsing data are normally deleted following processing in anonymous form but can be stored and used by the Company to detect and identify perpetrators of any computer offences committed to the detriment of the Website or using the Website. Without prejudice to this possibility and to the provisions of the Cookie Policy.
3. Cookies
We use cookies and other similar technologies such as tagging, embeddable scripts and local storage. Cookies are small text files that may be places on your computer or other device by websites when you visit them. Cookies enable us to recognise your device on a subsequent visit by that device to our Website and allow us to deliver a more personalised experience by providing information to us. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy
4. Why and how we process your personal data
We process your personal data to manage and operate our Website, providing you access to it, to improve it and to solve potential problems in accordance with the GDPR, Article 6 (1) (f). Processing is based on the Company's legitimate interest in presenting its activities to the public, ensuring the functioning of the Website, improving its appearance and user experience, such as:
- to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- to improve our Site to ensure that content is presented in the most effective manner for you and for your device.
- to allow you to participate in interactive features of our service, when you choose to do so.
- as part of our efforts to keep our Site safe and secure.
5. Disclosure of personal data
We may disclose personal data to third parties in certain circumstances, as detailed in the following list:
i. in the event that We sell or buy any business or assets, in which case We will disclose personal data regarding you to the prospective seller or buyer of such business or assets;
ii. if We are under a duty to disclose or share personal data regarding you in order to comply with any legal or regulatory obligation or request, or in order to enforce or apply our terms of use or to protect the rights, property, or safety of A. Menarini Farmaceutica Internazionale SRL (UK Branch), our customers, or others;
iii. to institutions, authorities, public bodies whether We are required to disclose personal data regarding you;
iv. third parties to whom We outsource services such as data hosting, analytics, marketing and Site development and maintenance.
v. to business partners, suppliers, and sub-contractors for the performance of any services We may provide for you or any interactions We may have with you as part of your use of the website, including the running and hosting of the website;
vi. and/or to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006, where necessary for the purpose of processing identified above;
vii. to professionals, independent consultants - working individually or in partnerships - and other third parties and providers which supply to the Company commercial, professional or technical services required to operate the Website (e.g., provision of IT and Cloud Computing services) for the purposes specified above.
The mentioned recipients shall only receive the data necessary for their respective functions and shall duly undertake to process them only for the purposes indicated above and in compliance with data protection laws. The data can furthermore be communicated to the other legitimate recipients identified from time to time by the applicable laws. With the exception of the foregoing, the data shall not be shared with third parties, whether legal or natural persons, who do not perform any function of a commercial, professional or technical nature for the Controller and shall not be disseminated.
The Data can be communicated also in countries outside the EU (“Third Countries”) to other companies of the Menarini Group for the same purposes and/or for administrative and accounting purposes pursuant to Article 6.1.(f) and Recital 48 of the GDPR.
Regarding any transfer of Data outside the EU, including in countries whose laws do not guarantee the same level of protection to personal data privacy as that afforded by EU Law, the Controller informs that the transfer shall in any event take place in accordance with the methods permitted by the GDPR, such as, for example, on the basis of the user’s consent, on the basis of the Standard Contractual Clauses approved by the European Commission, by selecting parties enrolled in international programmes for free movement of data or operating in countries considered safe by the European Commission.
This Privacy Policy applies only to the Website as defined above. Even though the Website may contain links to other websites (known as third party websites), please be informed that the Company does not perform any access or control over cookies, web beacons or other user-tracking technologies that may be active on such third party websites, on the contents and materials published thereon, or on their methods of processing of your personal data; for this reason, the Company expressly declines any liability for such matters. You should therefore verify the privacy policies of such third party websites and collect information about their terms and conditions and about how they process your personal data.
6. How we ensure your personal data’s security and quality
The Company undertakes to ensure security of the user’s personal data and comply with provisions on security provided by law to avoid data loss, illegitimate or unlawful uses of data or unauthorised access to data, with particular but not exclusive reference to Articles 25-32 of the GDPR. The Company uses many types of advanced security technologies and procedures intended to aid protection of the user’s personal data; for example, personal data are stored on secure servers situated on premises with protected and controlled access. The user can assist the Company to update and correct their personal data by communicating any change of address, qualifications, contact information, etc.
The security of personal data regarding you is a high priority. We take such steps as are reasonable to securely store personal data regarding you so that it is protected from unauthorised use or access, misuse, loss, modification or unauthorised disclosure. This includes both physical and electronic security measures.
Examples include the use of passwords, locked storage cabinets and secured storage rooms. Other features include:
- storing information on secured networks consistent with industry standards, which are only accessible by those employees who have special access rights to such systems.
- using industry-standard encryption technologies when transferring or receiving personal data, such as SSL technology.
- restrictions are placed on the electronic transfer of files; and
- our IT networks undergo necessary vulnerability testing to continually identify and remediate potential opportunities for unauthorised data access.
We take steps to destroy or de-identify personal data when the information is no longer required for any purpose for which it may be used or disclosed by us and We are no longer required by law to retain the information.
We will take all steps reasonably necessary to ensure that personal data regarding you is treated securely and in accordance with this Privacy Policy.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect personal data regarding you, or procure that personal data regarding you is secured, We cannot guarantee the security of such data transmitted to our Site; any transmission is at your own risk.
7. How we store data and for how long
In compliance with Article 5.1.(c) of the GDPR, the computers and programmes we use are set up in such a way to reduce the use of personal and identifying data to a minimum. Such data are processed only to the extent required to achieve the purposes indicated in this Policy, and will be stored for as long as strictly necessary for achievement of the specific purposes pursued - in any event, the criterion used to determine the storage period is based on compliance with time limits permitted by law and the principles of data minimisation, storage limitation or rational management of our records.
8. Your rights
You may at any time exercise the rights afforded by Articles 15-22 of the GDPR, such as the right to obtain confirmation of the existence of personal data which relate to you, check its content, origin, correctness, location (also with reference to any Third Countries), request a copy, request correction and in cases provided by law, restriction of processing, deletion, object to direct marketing activities. Likewise, you may always withdraw consent and/or make observations on specific issues regarding processing operations of your personal data which you regard as incorrect or unjustified by your relationship with the Company, or lodge a complaint with the Data Protection Authority.
You may contact the Controller and/or DPO at the addresses displayed above (paragraph 1. General) to make any requests regarding personal data processing by us, to exercise your legal rights and to obtain an updated list of the parties who have access to your data.
9. Changes to our Privacy Policy
We review and amend this Privacy Policy from time to time. Any changes We may make to this Privacy Policy in the future will be posted on the Site and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Site.
10. Contact
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to [email protected] or A. Menarini Farmaceutica Internazionale SRL (UK Branch) Menarini House, Mercury Park, Wycombe Lane, Wooburn Green, Buckinghamshire, HP10 0HH