PERSONAL DATA PROTECTION POLICY
1. Details of the personal data controller
INTELLECT PHARMA PLUS EOOD, registered with the Commercial Register of the Registry Agency, Unified identification code (UIC) 201238483, with registered address at: Manastirski livadi District, ul. Akademik Ilcho Dimitrov, 7B, 1618 Sofia, Bulgaria is a controller within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter the “Regulation”) and the Bulgarian Personal Data Protection Act (hereinafter the “PDPA”).
The website http://www.intellect-pharma.plus/ is owned and managed by INTELLECT PHARMA PLUS EOOD in full compliance with the Regulation and the PDPA.
Contact details of data protection officer
Mark Chepilev, Data Protection Officer
Tel: +359 888 910955
The purpose of this Policy is to provide information on the principles and manners in which INTELLECT PHARMA PLUS EOOD processes personal data in its capacity of controller, as well as on the rights of data subjects whose data is being processed.
3. Principles Personal data protection is a priority for INTELLECT PHARMA PLUS EOOD. INTELLECT PHARMA PLUS EOOD does not sell personal data collected by it to third parties, nor does it provide such data without lawful legal basis for that purpose as per the Regulation and the PDPA. INTELLECT PHARMA PLUS EOOD collects, processes and provides personal data to third parties only when there is a due and lawful legal basis for that, including freely given explicit consent within the meaning of the Regulation and/or other legal basis as provided for in the Regulation and/or the PDPA.
Personal data is provided to third parties only in case where: (1) INTELLECT PHARMA PLUS EOOD has entered into a contract with such third parties, which are INTELLECT PHARMA PLUS EOOD’s suppliers of services (contactors), and such third parties process data in the name of INTELLECT PHARMA PLUS EOOD in full compliance with the Regulation, the PDPA, the instructions of INTELLECT PHARMA PLUS EOOD under a written contract between INTELLECT PHARMA PLUS EOOD and the respective supplier (which includes personal data protection clause), provided that all such suppliers shall be obliged to apply the highest standards of personal data protection; (2) INTELLECT PHARMA PLUS EOOD has entered into a contract with third parties – producers of products to act as their distributor in Bulgaria and the provision of data is an obligation for INTELLECT PHARMA PLUS EOOD as per the respective contract between the producer and INTELLECT PHARMA PLUS EOOD (which includes personal data protection clause), provided that all such producers shall be obliged to apply the highest standards of personal data protection.
INTELLECT PHARMA PLUS EOOD acknowledges and appreciates the sensitivity of certain categories of personal data, such as for example data related to health, and for this very reason INTELLECT PHARMA PLUS EOOD takes special protection measures for such data, including anonymization, application of technical and organization measures for protection, etc.
INTELLECT PHARMA PLUS EOOD processes personal data in strict compliance with the principle of minimization of the data processed whereby data is processed only for specific, reasonable and legitimate purposes (need-to-know principle).
4. Personal data
Personal data means any information relating to an identified natural person or natural person that is identifiable on the basis of such information.
5. Personal data processing
INTELLECT PHARMA PLUS EOOD collects and processes personal data which is needed for carrying out the company’s activities. In that regard INTELLECT PHARMA PLUS EOOD processes personal data for the following purposes: (1) distribution in Bulgaria of pharmaceutical products, medical devices and cosmetics; (2) pharmacovigilance related to products and devices for which the company acts as distributor in Bulgaria and provision of information to the manufacturers on adverse effects or other health impact reported by patients; (3) ensuring sufficient personnel for conducting the company’s activities (including hiring of personnel, conclusion and performance of labor and civil contract, etc.).
6. Categories of processed personal data
INTELLECT PHARMA PLUS EOOD collects the following categories of personal data from the following data subjects:
6.1. Names, telephone numbers, specialization/education details, professional addresses and e-mails of natural persons who are employed by or represent companies that are contractual counterparties of INTELLECT PHARMA PLUS EOOD, as well as natural persons – medical representatives with whom INTELLECT PHARMA PLUS EOOD has established a partnership relation. The said data is collected for the purposes of performing INTELLECT PHARMA PLUS EOOD’s activities as distributor in Bulgaria of pharmaceutical products, medical devices and cosmetics, as well as for the purposes of bookkeeping and maintaining financial and business records as per the applicable Bulgarian legislation;
6.2. Data related to date of birth, age, sex, physical conditions of the patient (height, weight, etc.), data related to health affecting habits (such as smoking, etc.), as well as data related to use of medicines, data related to health of natural persons that have filed a notification for adverse effect or other impact on their health resulting from use of a product of a manufacturer that is a contractual partner of INTELLECT PHARMA PLUS EOOD. The said data is collected for the purposes of pharmacovigilance related to products and devices for which the company acts as distributor in Bulgaria and for the purposes of provision of information to the manufacturers on adverse effects or other health impact reported by patients. The said data shall be provided to third parties, including in non-EU countries, after duly performed anonymization. INTELLECT PHARMA PLUS EOOD does not provide to the manufacturers data identifying the individual patient that has filed the notification for adverse effect or other impact (such as names, PIN, address, etc.)
Cookies are small files with information sent from the web server and stored in the user’s Internet browser (for example, information on the selected language, connection time, visited websites) or on the hard drive, and then returned from the Internet browser to the server whenever access to this server is obtained by visiting the relevant website. INTELLECT PHARMA PLUS EOOD’s website uses the following cookies for the following purposes:
Every user may disable in his/her Internet browser the storing of cookies, as well as may delete the already stored cookies at any moment. Every user who wishes to proceed that way shall make the necessary changes in the settings of his/her browser and/or shall contact the browser’s provider for assistance.
INTELLECT PHARMA PLUS EOOD shall not be liable and shall be held harmless in case that the Internet browser used by the user does not allow to control the enabling/disabling of cookies, their blocking or the deletion of already stored cookies. If the user disables the cookies or deletes the already stored ones, then it is possible that the normal functioning of the website is technically disrupted for that user.
It is possible that under a law or in case of a court/arbitral/enforcement/security proceedings and/or upon request of a competent authority INTELLECT PHARMA PLUS EOOD discloses personal data, as well as in case that such disclosure is needed for the purposes of national security, law enforcement or other cases provided for in the law.
INTELLECT PHARMA PLUS EOOD may also disclose personal data when such disclosure is reasonably necessary for protecting INTELLECT PHARMA PLUS EOOD’s legitimate interests. In addition, in case of a merger or reorganization INTELLECT PHARMA PLUS EOOD may transfer any personal information collected to a new or merged/reorganized company.
8. Security measures
INTELLECT PHARMA PLUS EOOD takes sufficient technical and organizational measures to protect the personal data it processes from theft, misuse, unauthorized access, unauthorized disclosure, unauthorized deletion and any other unauthorized processing or disposal with such data. All employees and contractual counterparties of INTELLECT PHARMA PLUS EOOD are under a confidentiality obligation and have undertaken to apply strictly all laws and regulations related to personal data protection.
In the cases where INTELLECT PHARMA PLUS EOOD provides personal data to third parties, INTELLECT PHARMA PLUS EOOD applies mechanisms, including inter alia contractual ones, which guarantee that such data is processed and protected in compliance with the applicable laws.
9. Time limits for storing of data
INTELLECT PHARMA PLUS EOOD complies with the principle of storing data only for the time necessary for completing the purpose for which such data has been collected, unless the applicable laws require a longer storage period for such data.
INTELLECT PHARMA PLUS EOOD deletes and erases personal data under Section 6.1. above immediately after termination of the contract/agreement with the respective partner manufacturer of INTELLECT PHARMA PLUS EOOD and after expiry of the statutory time limits for storage of documentation according to the accountancy and tax legislation in the Republic of Bulgaria. The personal data of medical representatives is deleted and erased after the cooperation with them is finally terminated.
INTELLECT PHARMA PLUS EOOD deletes and erases personal data under Section 6.2. above after expiry of the statutory time limits related to the activities of the company, and in particular after expiry of the time limits applicable to pharmacovigilance as per the contracts concluded by INTELLECT PHARMA PLUS EOOD with the manufacturers of the respective products.
10. Personal data rights
Pursuant to the Regulation and the PDPA data subjects have the following rights at all times: (1) right of access to their personal data processed by INTELLECT PHARMA PLUS EOOD; (2) right of rectification of incorrect personal data, right of erasure (in case there is proper legal basis for that), right to restriction and blocking of processing of personal data processed by INTELLECT PHARMA PLUS EOOD (in case there is proper legal basis for that); (3) right to data portability under the conditions provided for in the Regulation; (4) right to object at any time to the processing of their personal data when there is proper legal basis for that; (5) right to file a complaint with the Bulgarian Personal Data Protection Commission in case where the data subject considers that his/her rights related to data protection have been breached.
INTELLECT PHARMA PLUS EOOD may refuse to grant requests for exercising of rights on a ground provided for in the Regulation and/or the PDPA, including in case of unreasonably repeating requests, requests that require unproportionate efforts and/or costs for the controller, as well as when the respective request is manifestly unfounded or when such request puts in danger or breaches the confidentiality and rights of other data subjects.
11. Entry into force and updates
This policy enters into force on 25 May 2018. INTELLECT PHARMA PLUS EOOD may amend and update this policy, whereas every such amendment or update shall be published in the official website of the company and, upon its sole discretion, INTELLECT PHARMA PLUS EOOD may also undertake other steps to inform users of the changes or updates in the policy.