We understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who uses our website and services and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”).
- Definitions and interpretation
The terms “processor”, “controller”, “processing” and “personal data” shall have the same meaning as stated in the General Data Protection Regulation.
The term “Service(s)” will mean the advancement of Pharmaceutical Medicine by enhancing the knowledge, expertise and skills of pharmaceutical physicians and other professionals involved in all scientific disciplines involved in the discovery, development, processing and usage of medicines as well as experimental and clinical research worldwide, leading to the availability and appropriate use of medicines for the benefit of patients and society.
- Information about us
The INTERNATIONAL FEDERATION OF ASSOCIATIONS OF PHARMACEUTICAL PHYSICIANS AND PHARMACEUTICAL MEDICINE (Hereafter referred to as: “IFAPP”) is a non-profit organization, with its head office in Woerden, the Netherlands. The registration number of the Dutch Chamber of Commerce is 30224375.
- What is personal data?
Personal data is defined by the GDPR as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
- What are my rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 12 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 14 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 14 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 14.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the competent supervisory authority. In Belgium this will be the Gegevensbeschermingsautoriteit: https://www.gegevensbeschermingsautoriteit.be/, for the UK: the Information Commissioner’s Office: https://ico.org.uk/]
- What personal data do we process?
In this section we have set out:
- The general categories of personal data that we may process;
- the purposes for which we may process personal data; and
- the legal bases of the processing.
Like many site operators, we collect information that your browser sends whenever you visit our website ("Log Data"). This information may include Internet protocol (IP) addresses, browser type and version, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data, number of visits, websites from which you accessed our site (Referrer), and websites that are accessed by your system via our site.
The processing of this data is necessary for the provision and the security of our website. The legal basis for this processing is our legitimate interest to monitor and improve our website and Services. We do not link these data to certain individuals. After the processing for the mentioned purposes, the data will be deleted.
We may process information relating to becoming an individual member of IFAPP (“Application Data”). The Application data may include your name, surname, employer/name of company, current position, address, email address, telephone number, professional qualifications, years of experience in the health care industry, functional and/or therapeutic area(s) of expertise and other CV information. The source of this information is you.
We require the Application Data so we are able to register you as an individual member. [DRAFT NOTE: Please mark the information that is absolutely necessary to become an individual member of IFAPP with an asterix to comply with the GDPR principle of data minimization. IFAPP can only process data that it needs to know, not that it would like to know. Information that IFAPP would like to know can only be processed on the legal basis of consent of the individual but in that case it must be clear that the field can be left blank.] The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
We may process information that you provide to us for the purpose of subscribing to our newsletters ("notification data"). The notification data may be processed for the purpose of sending you our newsletters. The legal basis of processing is consent.
We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
- Usage of personal data for direct marketing purposes
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and information about our Services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
- How long will we keep your personal data
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
- How and where do you store or transfer my personal data?
We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
- Do you share my personal data?
- Use of processor(s)
IFAPP is free to rely on data processors. A processor is the natural or legal person who processes your personal data upon request and on behalf of us, the controller. The processor is required to ensure the security and confidentiality of the personal data. The processor will always act on the instructions of the controller. We rely on processors for hosting purposes, administrative purposes and analytic purposes.
With a view to the optimal protection of your personal data, we have made the necessary contractual arrangements with our processors to ensure that they apply the highest privacy standards. In any event, data processors shall be required to ensure the security and confidentiality of the personal data.
- Transfer of personal data to third parties
IFAPP will not share any of your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, IFAPP may be legally required to share certain personal data, which might include yours, if IFAPP is involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
- How can I control my personal data?
In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via our website, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes, including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails or at the point of providing your details.
- How can I access my personal data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 14.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 15 working days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
- How do I exercise my rights?
If you wish to exercise your rights, you must send a written request and proof of identity by registered mail to IFAPP secretariat, Kuipersweg 2T, 3449 JA WOERDEN, The Netherlands or by email to email@example.com. We will respond as soon as possible, and no later than 1 month after receipt of the request.