OUR COMPANY DATA PRIVACY NOTICE

Last updated: 01 April 2021

Please note the following important information concerning the processing of your personal information when you use our web site and provide us with your contact information or in connection with your medical enquiry, complaint or adverse event report by Karo Pharma AB and its affiliates (hereinafter together called “Karo Pharma”). This notice will explain how Karo Pharma uses the personal data we collect from you when you provide us with a medical enquiry, complaint or adverse event report use our website https://www.kalknagelbehandeling.nl (the “Site“). This page informs you of our policies regarding the collection, use and disclosure of Personal Information.

Data controller
Karo Pharma is the data controller responsible for processing your personal information in accordance with applicable data protection legislation.

For what purposes do we use your personal information?

When you provide us with your contact information on our Site
Your Personal Information will be processed in order for us to provide you with content and services on your request. For example, if you indicate an interest in download white papers written by Karo Pharma, you are asked to submit your name and e-mail address, which we retain on file, so that we may send you the information that you requested.

If you provide us with your contact details by filling in the request form under the contact menu or e-mailing us, your Personal Information will be processed in order to us to contact you. We may retain a record of users who have contacted us in order to respond properly to questions or concerns and for purposes of future communications.

If you have provided us with your contact details, your personal information may be processed in order to contact you with marketing about our programs, products, features or services.

When you provide us with a medical enquiry, complaint, or adverse event report
Your Personal Information will be processed in order for Karo Pharma to comply with applicable laws and regulations.
Your Personal Information will be processed for the purpose of handling your medical enquiry, complaint, or adverse event report.

What Personal Information do we collect about you?
When you provide us with your contact information on our Site
Contact information such as name and e-mail address.

When you provide us with a medical enquiry, complaint, or adverse event report
Personal information that you have provided us with, which may include: your name (including name prefix or title); gender; home address; age and date of birth; email address; social media username; phone number(s) and special categories of personal information that you have provided us with, which may include: medical diagnostic data; prescription data; other health related information provided by you (such as health information, information concerning sex life and sexual orientation, disability and disability type, health risk factors, personal exposure and surveillance data); and relationship to a person (“Personal Information”).

How do we collect your Personal Information?
We collect and process the data when you provide us with any Personal Information about you by any communication methods. You can always choose to provide us with Personal Information. However, some Personal Information is necessary for us in order to comply with our legal obligations related to your medical enquiry, complaint or adverse event report.

On what legal basis do we use your Personal Information?

When you provide us with your contact information on our Site
Processing of Personal Information about you for the purpose to provide you with content and services on your request is based on our legitimate interest to respond to your request and provide you with the relevant material.
Processing of Personal Information about you for the purpose to contact you when you have filled out the contact form on our Site or e-mailed us is based on our legitimate interest to contact you or reply to you.
Processing of Personal Information about you for marketing purposes is based on our legitimate interest to direct marketing to you in order to inform you about our programs, products, features or services.

When you provide us with a medical enquiry, complaint, or adverse event report
Processing of Personal Information about you is required so that we can comply with our legal obligation to; monitor, collect and report any suspected adverse events to the regulatory authorities, and ensuring the provision of safety surveillance and continued monitoring of the benefits/risk balance for KARO Pharma’s medicinal products, medical devices and cosmetics.

Furthermore, processing of Personal Information about you for the purpose of responding to your medical enquiry or investigating your complaint is based on our legitimate interest as we would not be able to respond to your enquiry without processing your Personal Information.

How long will we keep your Personal Information?

When you provide us with your contact information on our Site
We will retain your Personal Information for as long as it is necessary for us to process your Personal Information for the purpose that we collected it for. When we no longer need your Personal Information, we delete it.

When you provide us with a medical enquiry, complaint, or adverse event report
We will retain your Personal Information for the period required by law, which is:
• In the case of an adverse event, a period of 10 years after a licence for the relevant product has expired or was cancelled anywhere in the world.
• In the case of medical enquiries, up to 3 years from the date of the enquiry.
Once an abovementioned period has expired, Karo Pharma shall delete your Personal Information.

With whom do we share your Personal Information?
By sharing your Personal Information, you agree that your Personal information will be accessible to Karo Pharma employees, as well as to authorised employees of certain suppliers and service providers of Karo Pharma who provide Karo Pharma with support services.
In addition, we may need to transfer your Personal Information processed for the purpose of handling a medical enquiry, complaint or adverse event report to certain regulatory authorities, within the EU and outside of the EU. Customarily, patients are not identified by Personal Information, such as name in reports to regulatory agencies.

Transfers of your Personal Information outside of your home country
Your Personal Information may be transferred to countries outside the European Economic Area. The countries to which we transfer Personal Information may not have data protection laws that provide an adequate level of protection to your Personal Information.
Karo Pharma shall take appropriate legal, and technical measures (which shall include entering into data transfer agreements based on the model clauses approved by the European Commission) to ensure that third parties to whom Karo Pharma transfer your Personal Information in those countries commit to ensure an adequate level of protection for your Personal Information. You can find more information about data transfer agreements here.

Protecting your Personal Information
Karo Pharma may share your Personal Information with suppliers and service providers following appropriate due diligence, in accordance with Karo Pharma’s policies and procedures, and under a written agreement which commits the suppliers and service providers to appropriate safeguards in relation to the handling of your Personal Information (including in relation to maintaining confidentiality of your Personal Information and implementing appropriate technical and organisational security measures).

Karo Pharma will take appropriate legal, organisational, and technical measures to protect your Personal Information consistent with applicable privacy and data security laws.

Opt-out from marketing e-mails
If we process your Personal Information for marketing purposes and you no longer wish to receive press releases or any other type of information from us, you may send us an email through our ”Contact Us” link or use the unsubscribe button in our e-mail forms to change your preferences.

Your data protection rights
With the exceptions stated in applicable data protection law, you are entitled to:
• right to access – request information regarding the processing of your Personal Information, including to be provided with a copy of your Personal Information;
• right to rectification – request the correction and/or deletion of your Personal Information, or object to the processing of your Personal Information;
• right to restriction – request the restriction of the processing of your Personal Information;
• right to object – object to the processing of your Personal Information, under certain conditions, such as but not limited to the extent this would not prejudice our ability to meet our legal obligations.
• right to data portability – request receipt or transmission to another organisation, in a machine-readable form, of the Personal Information that you have provided to KARO Pharma; and
• right to complain – complain to your local data protection authority, or to a court of law, if your data protection rights are violated. You may be entitled to claim compensation for damages or distress incurred or suffered in consequence of unlawful processing of your Personal Information.
If you would like to exercise your rights, please let us know by getting in touch using the contact details below. Karo Pharma will respond to your request without undue delay, but at the latest one month after receiving your request. This period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

Changes to our privacy notice
Karo Pharma reserves the right to update or change its privacy notice at any time and place any updates on this Site.

Cookies
Cookies/ Web server logs: Similar to other commercial web sites, our Site utilizes standard technology called ”cookies” and web server logs to collect information about how our Site is used. Cookies are a feature of web browser software that allows web servers to recognize the computer used to access a web site. Cookies are small pieces of data that are stored by a user’s Web browser on the user’s hard drive. Information gathered through cookies and Web server logs may include the date and time of visits, the pages viewed, time spent at our Web Site, and the Web sites visited just before and just after our Web Site. This information is collected on an aggregate basis. None of this information is associated with you as an individual.

You can, of course, disable cookies on your computer by indicating this in the preferences or options menus in your browser. However, it is possible that some parts of our Web Site will not operate correctly if you disable cookies. You should consult with your browser’s provider/manufacturer if you have any questions regarding disabling cookies.

We use non-identifying information collected on our Site in the aggregate to better understand your use of the Site and to enhance your enjoyment and experience. For example, we may use the information to improve the design and content of our Site or to analyze the programs and services that we offer.

Types of cookies on the Site:

• Necessary cookies: CookieConsent
• Name Provider: Cookiebot
• Purpose: Saves the cookie status of the user for the current domain
• Expires after: 1 year
• Type: HTTP

Statistical cookies:

• Name: _ga / _ga_# / _gat/ _gid
• Provider: Google Tag Manager
• Purpose:
  • _ga:Registers a unique IQ used to generate statistical data about how the visitor uses
  • _ga_#: Collects data on how many times a user visits the Site, and data for the first and most recent visit.
  • _gat: Used by Google Analytics to lower
  • _gid: Registers a unique ID used to generate statistical data to map how the visitor uses the website
• Expires after:
  • _ga: 2 years
  • _ga_#: 2 years
  • _gat: 1 day
  • _gid: Registers a unique ID used to generate statistical data to map how the visitor uses the website
• Types:  HTTP

Contact us
If you have questions or requests regarding the processing of your Personal Information, or require additional information, please contact:
Data Protection Officer
E-mail: [email protected]
Version: 2.0