PRIVACY NOTICE - vendors, customers, and partners

The data controller is Pharmacosmos A/S, Roervangsvej 30, DK-4300 Holbaek, Denmark.

Pharmacosmos A/S will collect and process your Personal Data for the purposes described below. 

To carry out our professional collaboration with the company you represent:
Your professional contact information such as your name, email, phone number, title, and work 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 General Data Protection Regulation (“GDPR”), article 6(1)(f) - legitimate interest. Our legitimate interest is to communicate with you as a representative of a company that we have or may have contractual relations with.

Compliance with applicable pharma related law and regulations:
As a pharmaceutical company, we are sometimes legally required to process Personal Data. This applies e.g. in respect of supplier evaluation and handling of quality complaints.

For these purposes, we might process your Personal Data, such as your name, email, phone number, title 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, email, phone number, title, address and sometimes also a 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, email, phone number, title, work address and bank information when you are or the company you represent is part of a financial transaction with us.

Our legal basis for such processing is the GDPR article 6(1)(b) - performance of a contract – in situations where we have a contractual relation with you, or the GDPR article 6(1)(f) – legitimate interest - in situation where you are a representative of a company that we have a contractual relationship with. Our legitimate interest is to communicate with you as a representative of a company that we have financial transactions with.

We may also be under a legal obligation to process your Personal Data in connection with the financial transactions in which case the legal basis we rely on is the GDPR, article 6(1)(c) - compliance with a legal obligation.

You receive our newsletter
We provide partners, affiliates, customers etc. with our newsletter and process name and email on recipients. 

Our legal basis for such processing is the 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 and in that connection process such persons’ names, addresses, titles, birthdays, shareholding details and other personal data needed to complete the screening in accordance with applicable legislation. 

Our legal basis for such processing is the GDPR article 6(1)(c) – processing is necessary to comply with our legal obligations.

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 A/S or a third party hosting provider.

When needed Pharmacosmos A/S may transfer your Personal Data to our affiliated companies, to third party service providers who deliver services to Pharmacosmos, or to relevant public authorities, if required by law. 

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 A/S 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 in countries outside the EU/EEA, not ensuring an adequate level of data protection, the transfer will be based on Intra-Group Agreements including the EU Commission’s Standard Contractual Clauses.

Transfers to third parties in countries outside the EU/EEA, not ensuring an adequate level of data protection, will be safeguarded by ensuring that the third party enters into the EU Commission’s Standard Contractual Clauses. 

You may request a copy of the relevant Standard Contractual Clauses by contacting Pharmacosmos A/S on: dataprotection@pharmacosmos.com. 

Your Personal Data will be retained for as long as it is relevant to fulfill the purpose for which it has been registered. 

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.

When we process personal data about you, you have a number of rights under the GDPR. These rights are stated below, but please note that certain limitations, restrictions, and conditions may apply to your ability to exercise these rights. Subject to those limitations, restrictions, and conditions, your rights are: 

Right of access
You have the right to access the personal data that we process about you and obtain certain other information relating thereto.

Right to rectification and erasure
You have the right to have inaccurate or incomplete personal data about you corrected or completed and to have your personal data erased by us.

Right to restriction of processing
You have the right to obtain restriction of our processing of your personal data in specific situations.

Right to data portability
Where our processing of your personal data is based on your consent or is necessary for the performance of a contract with you and the processing is carried out by automated means, you have the right to receive the personal data about you in a structured, commonly used and machine-readable format (data portability). You may request that we transmit your personal data directly to another data controller where technically feasible.

Right to object to our processing
Where our processing of your personal data is based on our performance of a task carried out in the public interest, cf. the GDPR article 6 (1) e., or our legitimate interests, cf. the GDPR article 6 (1) f., you have the right to object, on ground relating to your particular situation, to our processing of your personal data. 

Right to withdraw your consent
Where our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. This shall not affect the lawfulness of our processing based on your consent before the withdrawal.

Automated individual decision-making
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

Right to complain to a supervisory authority
You have the right to lodge a complaint with a supervisory authority such as the Danish Data Protection Agency (Datatilsynet).

If you want to exercise any of the above rights, please contact our Data Protection Manager at dataprotection@pharmacosmos.com. Please note that we may require proof of your identity and full details of your request before processing it. The data will only be used to verify your identity and will not be stored for longer than needed for this purpose. 

If you wish to lodge a complaint with the Danish Data Protection Agency, you may also contact it directly at dt@datatilsynet.dk.

If you have questions or you do not feel that your concerns have been addressed in this Privacy Notice, please contact us either by mail, Attention: “Data Protection Manager” to the address: Pharmacosmos A/S, Roervangsvej 43, DK-4300 Holbaek, Denmark or by email to: dataprotection@pharmacosmos.com

From time to time, we may revise this Privacy Notice. Any such changes to this Privacy Notice will be reflected on this page. Pharmacosmos A/S recommends that you review this Privacy Notice regularly for any updates. The date on which this Privacy Notice was last revised is located at the top of this Privacy Notice.