Full privacy notice

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About us

This Privacy Policy applies to the website www.slaviapharm.ro (hereinafter the “Website”), owned by SLAVIA PHARM S.R.L., with its registered office in Bucharest, 44C Theodor Pallady Blvd., 032266, District 3 (“Slavia Pharm”), where we collect certain personal information about you.

Please read this Privacy Policy carefully, as it contains information about how we use the personal data you provide to us or that we otherwise collect in connection with the Website (hereinafter “Personal Data”). Slavia Pharm is the controller of the Personal Data.

You can contact us at dpo@slaviapharm.ro for any additional information regarding how we use your data. In addition, please read our Cookie Policy (available at www.slaviapharm.ro/politica-cookie).

We reserve the right to update this Policy, as well as the Cookie Policy. Please check this section periodically. Any changes will be posted on the Website.

1. Purpose and method of data processing

You can use almost all of our website without having to provide us with any Personal Data. However, for certain sections you must provide us with Personal Data so that we can communicate with you or record your requests. In addition to the information you must provide, we collect certain information when you visit the Website.

Pharmacovigilance

Our website includes a form dedicated to reporting adverse drug reactions, in accordance with the legal obligations applicable to Slavia Pharm as marketing authorisation holder.

Personal data	Data about the reporting person (first name, last name, contact address), data about the patient (including health data: age, sex, diagnosis, adverse reaction, suspected medicinal product), to the extent voluntarily provided
Legal basis for processing	Legal obligation (Art. 6(1)(c) GDPR in conjunction with Art. 9(2)(i) GDPR) – Regulation (EC) No 726/2004, Regulation (EU) No 520/2012, Law No 95/2006 on healthcare reform
Who we disclose the data to	The European Medicines Agency (EMA), the National Agency for Medicines and Medical Devices (ANMDM), the Ministry of Health, licensing partners/licensees, pharmacovigilance service providers, IT providers
How long we will store the data	For the validity period of the marketing authorisation and for at least 10 years after its expiry, in accordance with applicable legislation
Where the data is stored	On the servers of Slavia Pharm or of contracted IT service providers located in Romania/the EEA. Transfers outside the EEA are carried out with the safeguards provided for in Chapter V GDPR (standard contractual clauses approved by the European Commission)

Contact section

If you send us a request through the contact form available on the Website or by email, we will use the data you provide exclusively to handle that request.

Personal data	First name, last name, email address, phone number, and any other data you send us in your message
Legal basis for processing	Legitimate interest (Art. 6(1)(f) GDPR) – handling the request or complaint submitted
Who we disclose the data to	IT service providers, technical support service providers, regulatory authorities where required by legal obligations
How long we will store the data	Until the request is resolved and no longer than 30 days from the last communication regarding the request
Where the data is stored	On Slavia Pharm servers in Romania/the EEA

Information about your visit, traffic analysis and Website optimisation

When you access our Website, we automatically collect certain technical data and data about traffic sources through online identifiers (cookies and IP address). This data is used both to ensure the security and optimisation of the website and, with your consent, for traffic analysis and visitor source attribution.

Personal data	IP address, general location (city level), browser type, operating system, time of access, page accessed, browsing history, device information, timestamp, traffic source (channel, source, medium, keyword, campaign)
Legal basis for processing	Legitimate interest (Art. 6(1)(f) GDPR) – for technical data related to website security and operation (server logs, error detection); Consent (Art. 6(1)(a) GDPR) – for analytics and tracking cookies (Google Analytics, SourceBuster.js), in accordance with the Cookie Policy
Who we disclose the data to	Google LLC (Google Analytics), SourceBuster.js, IT and technical support service providers, authorities based on legal obligations
How long we will store the data	Technical data (server logs): maximum 6 months. Analytics and tracking cookies: see the Cookie Policy for storage periods per category
Where the data is stored	On Slavia Pharm servers in Romania/the EEA; Google – outside the EEA, with the safeguards of Chapter V GDPR (standard contractual clauses, Decision (EU) 2021/914)

2. Security of personal data

We take appropriate technical, physical and organisational measures to protect the Personal Data collected through the Website against misuse, destruction, loss, alteration, disclosure or unauthorised access, in accordance with applicable data security and privacy legislation. However, no internet-based website can be 100% secure.

Our Website may contain links to other websites. We are not responsible for the privacy practices of those websites. We advise you to always read the privacy policies of the websites you visit.

If you suspect that the confidentiality of your Personal Data has been compromised, please contact us immediately at dpo@slaviapharm.ro.

3. Retention of personal data

We will retain your Personal Data for as long as necessary to provide you with the requested services, in accordance with applicable legal deadlines, or for any of the other purposes listed in this Privacy Policy. The specific retention period is stated for each relevant purpose in the tables above.

We will take reasonable steps to delete or anonymise the Personal Data we hold if it is no longer needed for the stated purposes or after the applicable retention period has expired.

4. Cookies

A significant part of the information mentioned in this Privacy Policy is collected through the use of cookies and similar techniques. Cookies are small text files containing small amounts of information that are downloaded and stored on your device.

Where required, you will be asked for your consent to the use of non-essential cookies. For more information about the cookies we use and how we use them, please see our Cookie Policy, available at www.slaviapharm.ro/politica-cookie.

5. Privacy of minors’ data

The Website is not intended for use by persons under the age of 18. We do not knowingly collect Personal Data from minors. If we discover that a minor has provided us with personal data, we will promptly delete that data.

6. Your rights

As a data subject, you have specific rights regarding the personal data we collect from you. Slavia Pharm will respect your individual rights and will address your concerns appropriately.

Right to withdraw consent (Art. 7(3) GDPR)

You may withdraw your consent to the processing of your personal data at any time, where the processing is based on consent. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Right to rectification (Art. 16 GDPR)

You may obtain the rectification of inaccurate personal data or the completion of incomplete data concerning you.

Right to restriction of processing (Art. 18 GDPR)

You may obtain the restriction of the processing of your personal data in the situations provided for in Art. 18 GDPR, including: contesting the accuracy of the data, unlawful processing, or the need for the data to establish, exercise or defend a legal claim.

Right of access (Art. 15 GDPR)

You may ask us for information about the personal data we hold about you, including a free copy of that data.

Right to erasure (Art. 17 GDPR)

You may obtain the erasure of your personal data in the cases provided for in Art. 17 GDPR, except where the processing is necessary to comply with a legal obligation or to establish, exercise or defend a legal claim.

Right to object (Art. 21 GDPR)

You may object – at any time – to the processing of your personal data carried out on the basis of legitimate interest (Art. 6(1)(f) GDPR), on grounds relating to your particular situation. We will no longer process the data unless we can demonstrate compelling legitimate grounds that override your interests.

If your data were processed for direct marketing purposes, you have the right to object to such processing at any time, without having to give a specific reason. Slavia Pharm does not currently carry out direct marketing activities through this website.

Right to data portability (Art. 20 GDPR)

Where the processing is based on consent or on the performance of a contract and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used and machine-readable format.

Note: in the context of this Policy, this right does not apply to processing carried out on the basis of a legal obligation (pharmacovigilance) or legitimate interest (contact form, technical browsing data).

Right to lodge a complaint (Art. 77 GDPR)

In the event of an alleged breach of personal data protection legislation, you may lodge a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP), 28-30 G-ral. Gheorghe Magheru Blvd., District 1, 010336, Bucharest, email: anspdcp@dataprotection.ro, www.dataprotection.ro