GENESIS PHARMA (CYPRUS) LTD
November 25th, 2019
Genesis Pharma (Cyprus) Ltd (referred to as ‘we’, ‘us’, ‘our’ “Genesis” or “Genesis Pharma”) respects your privacy and is committed to protecting and handling your data in an open and transparent manner and in compliance with the applicable laws, including Regulation 2016/679/EU (GDPR).
- Genesis Biopharma Romania SRL
- Genesis Pharma Bulgaria EOOD
- Genesis Pharma Adriatic d.o.o.
1. Who we Are
Genesis Pharma (Cyprus) Ltd is a pharmaceutical company registered in Cyprus (Reg.No. C107632) with mission to ensure that patients in the countries we operate have direct access to innovative biopharma therapies. Registered office and head offices at:
73 Metochiou Street
3rd Floor, 2407 Engomi
Tel: 00357 22769946
Fax: 00357 22769978
And with subsidiaries located in Romania, Bulgaria and Croatia.
Identity and contact details of the Controller and the Data Protection Officer
Genesis Pharma (Cyprus) Ltd
73 Metochiou Street
3rd Floor, 2407 Engomi
Tel: 00357 22769946
Fax: 00357 22769978
or its subsidiaries:
Genesis Biopharma Romania SRL,
Calea 13 Septembrie nr.90,
Office No. 1.04, 1st floor
District 5, Bucharest
Tel: +40 (0) 21 403 40 74
Fax:+40(0) 21 403 40 75
Genesis Pharma Bulgaria EOOD
INTERPRED-World Trade Center Sofia
36 Dragan Tsankov Blvd.
Office 702, 7th Floor
Tel: +359 2 969 3227
Fax:+359 2 969 3228
Genesis Pharma Adriatic d.o.o.
Perjasička 1B, 10000 Zagreb, Croatia
Tel: +385 1 5530011
Fax: +385 1 5813666
DPO: Mr. Charalampos Kamarinopoulos, Data Protection Officer, tel: 00357 22769946, email: email@example.com
2. Collection and processing of personal data
We collect and process personal data from different sources:
- Directly provided from you to our employees in the frame of our business relationship and/or a contractual relationship,
- Directly from you because you have requested information or showed interest about our products,
- Directly from you because of information provided related to our products,
- Lawfully collected and processed from publicly available sources (directories, events, public presentations, conferences, specialty associations etc.)
3. Purpose of the processing and the legal basis for the processing
Your personal data may be processed by the Company in its capacity of Data Controller in accordance with the GDPR and the local data protection law for at least one of the following reasons (Legal Basis):
- To execute a contract,
- To comply with a legal and/or regulatory obligation,
- To Safeguard our legitimate or third-party interests, respectively Data and/or information are processed under this ground for reasons pertaining to business and/or commercial interests, taking into consideration the necessity of such action and your interests, fundamental rights and freedoms, for example:
(a) monitoring and assessing compliance with the company’s policies and procedures;
(b) ensuring the smooth operation and security of our IT system;
(c) safeguarding our records and documents, for example through data and record management;
(d) Pursuing and/or defending claims in judicial and/or regulatory proceedings;
(e) Protecting our Intellectual Property rights;
(f) Preventing or detecting crimes and fraud by for example establishing video surveillance (CCTVs), with the observance and within the limits of the applicable legislation;
(g) Transferring, assigning and/or sale of any or all of our rights, titles or interests under any agreement between you and us;
(h) ensuring the operation, evaluation and improvement of our business;
- You have provided your consent
4. Categories of personal data
Personal data is data which can be used to identify you. This may include Name, Surname, Address, Phone number, mobile phone number, email, Specialty, Institution and job function, ID/Passport number etc.
Sensitive personal data is information related to any of the following: racial or ethnic origin, political opinions, religious beliefs, trade union membership, health, sex life, criminal offences and convictions.
5. Minors’ Data
We understand and respect the importance of protecting the privacy of minors. We may process the personal data of minors only with the prior authorisation and/or consent of their parents or legal guardians or as otherwise required or permitted by law.
6. Any recipient or categories of recipients of the personal data
In order to execute contractual obligations, compliance purposes or legal obligations and to safeguard legitimate interests, data may be provided to several departments in the company and in companies, members of the Genesis Pharma Group. In relation to the above obligations and purposes, data may be communicated to other companies, such as:
- To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary as a matter of applicable law or regulation,
- payroll companies,
- banking and other financial institutions executing payments,
- accounting services companies,
- third party service providers,
- medicinal product manufacturers/suppliers,
- IT and “Cloud Computing” service providers,
- travel agencies and conference organizers,
- professional service providers,
- companies that perform tasks on our behalf.
All appointed data processors processing personal data on our behalf are contractually bounded to comply with the GDPR Article 28, as well as with all other applicable requirements.
7. Details of transfers to third country and safeguards
Your personal data may be transferred to third countries outside the EEA to fulfill a contractual obligation or a legal obligation or based on your consent given to us to do so. Third parties acting as Data Processors in third countries are obligated to comply with the GDPR and to provide appropriate safeguards in relation to the transfer of your data, on the basis of either an adequacy decision issued by the European Commission pursuant to Article 45 of the GDPR, or contractual obligation or other appropriate safeguards pursuant to Article 46 of the GDPR. You may obtain a copy of the above by contacting Genesis Pharma or any of its subsidiaries at the contact details mentioned further above in this Policy.
8. Retention period and/or criteria used to determine the retention period
Data are processed both in paper and electronic forms and are stored into the company system in line with the applicable laws, including the aspects pertaining to data security and confidentiality, and according to the principles of fair and lawful processing. Your Data shall be stored only as long, as strictly necessary to fulfil the goals for which they were collected; in any case, the criterion used to determine the length of the storage period takes into due account the need to comply with any relevant legal requirements, and the need to manage the Company’s records. We may store your data even after the end of our relationship, but only for as long as necessary to fulfil contractual and legal obligations. We update and maintain our databases to ensure your Data are always correct and accurate.
9. To exercise your rights
a) Receive access to your personal data. In order to receive a copy of your personal data you can contact Genesis Pharma at the provided in this Policy contact information.
b) Request rectification/correction of the personal data we hold about you. This enables you to correct the data we keep about you.
c) Request erasure of your personal information (right to be forgotten). This enables you to request the erasure of your personal data if there is no legitimate reason for us continuing to process it.
d) Object to processing of your personal data where we are relying on a legitimate interest and there is something specific about you that makes you want to object to processing. If you lodge an objection, we will no longer process your personal data unless we can demonstrate the legitimate grounds for the processing which override your interests, rights and freedoms.
e) Object to processing of your personal data, for direct marketing purposes. This also includes profiling for direct marketing purposes - If you object to processing for direct marketing purposes, then we shall stop the processing of your personal data for such purposes.
f) Request the restriction of processing of your personal data. This enables you to ask us to restrict the processing of your personal data, i.e. use it only for certain things, if: it is not accurate, it has been used unlawfully but you do not wish for us to delete it, it is not relevant any more, but you want us to keep it for use in possible legal claims, you have already asked us to stop using your personal data but you are waiting us to confirm if we have legitimate grounds to use your data.
g) Data portability, request to receive a copy of your personal data in a machine-readable format that is structured and commonly used and transfer the data to another organization. You also have the right to have your personal data transferred directly by Genesis to other organizations of your choice.
10. The right to withdraw consent at any time
When we process your data based on your consent, you have the right to withdraw you consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before it was withdrawn or revoked by you.
11. The right to lodge a complaint
If you have exercised any of your data protection rights and your request has not been adequately addressed by us, you have the right to:
- Complain by contacting Genesis Pharma at the provided in this Policy contact information.
- Filing a complaint to the applicable competent supervisory authority.
12. Where the provision of personal data is part of a statutory or contractual requirement or obligation
For the purpose of entering into a business relationship you must provide your personal data which are necessary for the execution of a business relationship and the performance of our contractual obligations.
Please note that failure to provide us with the required data may forbid us from entering into a business relationship.
13. The existence of automated decision making, including profiling
In general, we do not conduct automated individual decision-making during our professional activities.
In some cases we may conduct automated processing of personal data to evaluate certain personal aspects (profiling) necessary for the performance or entering into a contract, for example in the following cases:
- Invitations to conferences and scientific meetings;
- Selection based on the specialty when introducing a new drug on the market;
14. Processing for marketing purposes and profiling
We may use your personal data to inform you about our products and services based on your explicit consent, and in some cases on our legitimate interest.
You have the right to object at any time to the processing of your personal data for marketing purposes, which includes profiling, by contacting Genesis Pharma or the DPO of the company at firstname.lastname@example.org
16. Data Security