Privacy Notice

This data protection notice is designed to inform you of what purposes Clonmel Healthcare Gurtnafleur Road, Clonmel, Co. Tipperary, Ireland (henceforth “we” or “us”) process your personal data for. Personal data means any information relating to you personally. The following information explains how your personal data is processed and ensures transparency.

We process the following personal data for the following purposes:

1. Data from business partners / customer data / supplier data

This encompasses any data from customers or business partners processed in the course of a business relationship with us. This applies in particular to the following personal data: contact details of our business partners (name, position, business contact details, e-mail address, telephone and fax numbers and information about the business relationship).

We process this data for the purpose of conducting the business relationship, concluding contracts, processing orders, carrying out analyses and evaluations. Processing is carried out on the basis of Article 6 (1) 1 b, f GDPR. If the basis for the processing is a legitimate interest within the meaning of Article 6 (1) 1 f GDPR, our legitimate interest lies in responding to inquiries and conducting business contact relationships. The provision of your personal data is required for the business relationship. This means that if you decide not to provide us with your personal data, it is not possible to conduct the business relationship.

We transfer your personal data to the following categories of recipients: service providers and/or companies within the STADA group as required to process your request. This includes both STADA companies in Germany and, if applicable, abroad. Categories of external service providers may be: IT service providers, waste disposal service providers, shipping services, auditors, consultants or authorities. In some cases both the STADA companies and potential service providers that we may transfer your personal data to may be located outside the EU.

2. Sales department, in particular field sales force

Our sales department processes the personal data of pharmacists and doctors that is required to perform its tasks. This includes in particular the following personal data: Data on doctors and pharmacists and, if applicable, their employees who are contacted and visited by the field staff (name, position, business contact information, e-mail address, telephone and fax number), or who are contacted by the sales department.

We process this data in order to sell our products and to maintain the data in our CRM systems. The field sales force processes this data for the purpose of notification, execution and follow-up of field service visits. Furthermore, the data may be used to conduct business analyses, for instance analysis of sales figures, trends, etc. Processing is based on Article 6 (1) 1 b, f GDPR. If the basis for the processing is legitimate interests within the meaning of Article 6 (1) 1 f GDPR, our legitimate interest lies in optimizing sales processes and marketing campaigns.

If data is collected directly: providing your personal data is not a legal or contractual requirement. This means that you are not obligated to provide us with your personal data. If you decide not to provide us with your personal data, the sales department will not be able to contact you. We transfer your personal data to the following categories of recipients: Affiliated companies for CRM maintenance, IT service providers, and in some cases disposal service providers, pharmacy cooperations, shipping services, consulting companies or marketing services.

Your data is processed mainly in Ireland. However, it may also be possible for foreign affiliated companies to access the data, for example for the purposes of maintaining our IT systems.

3. Staging competitions/lotteries and surveys

We regularly stage competitions/ lotteries and surveys with different target groups. We process personal data on those participating in the competition or survey (in particular name, position, business or private contact information, e-mail address, telephone number).

We process this data for the purpose of staging the competition or the surveys. The data is processed in accordance with Article 6 (1) 1 a GDPR.

You are not legally required to provide your personal data, but this is often necessary to participate in the competition/survey. This means that you are not legally obligated to provide us with your personal data. If you decide not to provide us with your personal data, usually it is not possible for you to participate in the competition or survey.

We may transfer your personal data to the following categories of recipients: Affiliated companies and, where applicable, external service providers (shipping companies, IT service providers, waste disposal services; publishers and web media producers) entrusted with processing or evaluating the competition or survey.

We only process your data within Ireland.

4. E-mail correspondence

We process the following personal data in the scope of e-mail correspondence: Personal data of the senders and recipients of e-mails (in particular name, position, business or private contact information, e-mail address, telephone number, fax number) as well as other personal data you may disclose about yourself through your signature or in the text of the e-mail.

We process this data to communicate with all stakeholders. The legal basis for processing this data is Article 6 (1) 1 a, f GDPR. If the basis for the processing is legitimate interests within the meaning of Article 6 (1) 1 f GDPR, our legitimate interest lies in responding to inquiries and conducting business communication.

You are not legally required to provide your personal data, but this is necessary in order to communicate by e-mail. This means that you are not legally obligated to provide us with your personal data. If you decide not to provide us with your personal data, communication by e-mail is not possible.

Where necessary, we transfer your personal data to the following categories of recipients: employees of affiliated companies as well as external service providers assisting us in responding to the request, such as IT service providers, consulting firms or auditors.

In some cases, affiliated companies and also service providers that we may transfer your personal data to are located outside the EU.

5. Contact initiated using Clonmel Healthcare Group’s digital channels (health data)

When responding to inquiries received at Clonmel Healthcare functional mailboxes, such as info@clonmel-health.ie, via social media channels or via our contact pages on the Internet, we process all the data provided by the sender of the inquiry (name, company, position, business or private contact information, e-mail address, telephone number, fax number) as well as additional personal data you may disclose about yourself in writing or orally in the text of the message or in the further course of processing of the inquiry. This may also be health data.

We process this data in order to be able to answer your inquiry. If you report side effects to us through these channels, the inquiry is immediately forwarded to the responsible colleagues at the drug safety department.

The legal basis for this is our legitimate interest under Article 6 (1) f GDPR.

You are not legally or contractually required to provide your personal data. This means that you are not obligated to provide us with your personal data. If you decide not to provide us with your personal data, this has the following consequences: it will not be possible to process your request.

We transfer your personal data to the following categories of recipients: recipients entrusted with processing your request or inquiry. These may be employees of affiliated companies as well as external service providers, e.g. IT service providers, consulting firms and partner laboratories.

If your inquiry involves a foreign country, your data may also be transmitted to affiliated companies abroad. Some of these are located outside the EU.

6. Business cards policy

Business cards are exchanged routinely in the scope general business contacts, trade fairs or similar events. We process the personal data contained on the business card in order to possibly initiate contact at a later time, or to update our data and may enter the data into our Outlook address book or our CRM system.

You are not contractually or legally required to provide your personal data. This means that you are not obligated to provide us with your personal data. If you decide not to provide us with your personal data, this has the following consequences: We do not receive and consequently do not use your business cards.

The legal basis for this is our legitimate interest under Article 6 (1) f GDPR.

We may transfer your personal data to the responsible contact person in the Group. If the matter relates to something abroad, your data may also be transmitted to affiliated companies abroad. Some of these are outside the EU.

7. Video surveillance

Some areas of our sites are under video surveillance. In this context, footage data as well as time and geographical data on persons on our premises is processed.

We process this data to ensure security at our sites. The legal basis for this is our legitimate interest within the meaning of Article 6 (1) f GDPR in the safety of our sites.

You are not legally or contractually required to provide your personal data. This means that you are not obligated to provide us with your personal data. If you decide not to provide us with your personal data, however, it is not possible for you to visit Clonmel Healthcare sites.

We transfer your personal data to the following categories of recipients: security service providers, IT service providers and in some cases, if there are substantiated grounds for suspicion, to external authorities.

Processing takes place exclusively in Ireland.

8. Advertising by fax, telephone and e-mail

We conduct advertising and information measures to make our customers aware of current offers, information and services. We process the following personal data in this context: Name, position, business contact information, e-mail address, telephone number, fax number.

The legal basis for this processing is your consent (Article 6 (1) a GDPR) or our legitimate interest (Article 6 (1) f GDPR).

You are not legally or contractually required to provide your personal data. This means that you are not obligated to provide us with your personal data. If you decide not to provide us with your personal data, it is not possible to receive information/advertising through the above-mentioned channels for which you have not given your consent or for which Clonmel Healthcare cannot claim a legitimate interest.

We transfer your personal data to the following categories of recipients: call centres, postal services, shipping companies, printers and IT service providers.

Your data will be processed mainly in Ireland. However, it may also be possible for foreign affiliated companies to access the data, for example for the purposes of maintaining our IT systems.

9. Registering for events

We invite individuals to events directly or indirectly through third parties. In the scope of staging such events, we process the following personal data of the participants: Name, position, contact information, e-mail address, telephone number, fax number.

The legal basis for processing your personal data is your consent (Article 6 (1) a GDPR). You are not legally required to provide your personal data, but this is required in order to register for the event. This means that you are not obligated to provide us with your personal data. If you decide not to provide us with your personal data, you will not be able to participate in the event.

If data is not collected directly, then we receive your personal data from the place where you registered for the event, for example from the organizer or through Xing Events. Depending on the type of event, the data may or may not be publicly available. For example, the participants at a specific event may be displayed publicly on Xing Events.

We transfer your personal data to the following categories of recipients: service providers assisting us in organising the event, shipping services for the purposes of sending invitations and/or information material and IT service providers.

Your data will be processed in Ireland. It is possible that your data may also be processed abroad.

10. Newsletters

We offer different ways to subscribe to newsletters. In the scope of sending newsletters, we process the following personal data of newsletter recipients: Form of address, title, name, institution, position, address, telephone number, e-mail address and possibly your customer number.

The legal basis for this processing is your consent (Article 6 (1) a GDPR) or our legitimate interest (Article 6 (1) f GDPR). You are not legally required to provide your personal data. This means that you are not obligated to provide us with your personal data. If you decide not to provide us with your personal data, you will not be able to receive our newsletters.

We transmit your personal data to agencies in order to send the newsletter. Your data will be processed mainly in Ireland. However, it may also be possible for foreign affiliated companies to access the data, for example for the purposes of maintaining our IT systems.

11. Visitor book/visitor management system

When visiting our locations, visitors (employees of external companies or other visitors) are requested to register in our visitor book/visitor management system or they are entered in such a system. We process this data to ensure security at our sites. The legal basis for this is our legitimate interest within the meaning of Article 6 (1) f GDPR in the safety of our locations.

You are not legally required to provide your personal data, but this is necessary to ensure security at our sites. This means that you are not legally obligated to provide us with your personal data. If you decide not to provide us with your personal data, you cannot enter our locations.

If needed, we transfer your personal data to the following categories of recipients: security service providers, IT service providers, waste disposal services, possibly to auditors and, in the event of substantiated suspicions, possibly to external authorities.

Processing takes place exclusively in Ireland.

12. Requests for samples (health data in some cases)

We offer the possibility of receiving samples of our products in the scope of marketing campaigns. If you decide to order these samples, we will process the following personal data on you: Name, title, contact details, e-mail and possibly your telephone and fax numbers and, if applicable, data on your illness for the purpose of processing the sample requests.

The legal basis for processing is our legitimate interest pursuant to Article 6 (1) a GDPR. You are not legally or contractually required to provide your personal data. This means that you are not obligated to provide us with your personal data. If you decide not to provide us with your personal data, however, it will not be possible to process your request or, in turn, to send the requested samples.

We transfer your personal data to the categories of recipients assisting us in this process; this includes in particular IT service providers and shipping services.

Your data will be processed mainly in Germany. However, it may also be possible for foreign affiliated companies to access the data, for example for the purpose of maintaining our IT systems.

13. Publication of photos and videos

At internal and external events, we may take photos and videos. This involves processing the footage or images of the persons concerned and possibly the names of the persons depicted. The purpose of this processing is to carry out internal and external communication measures.

The legal basis for this processing is your consent (Article 6 (1) a GDPR).

You are not legally or contractually required to provide your personal data. This means that you are not obligated to provide us with your personal data. If you decide not to provide us with your personal data, no photos of you will be taken or published.

We transfer your personal data to the categories of recipients assisting us in this process; this includes in particular IT service providers.

Your data will be processed mainly in Ireland. However, it may also be possible for foreign affiliated companies to access the data, for example for the maintenance of our IT systems.

If individual service providers or affiliated companies are located outside the EU, there may not be an adequate level of data protection compared to the level of data protection within the European Union. This means that the data protection laws in this country, to which your data may be transferred, do not offer the same protection as in Ireland.

You are entitled under the EU General Data Protection Regulation to enforce the following rights against us: • Right of access

• Right to rectification • Right to restriction of processing • Right to erasure/Right to be forgotten • Right to data portability • Right to object

If you wish to exercise any of the above rights or to contact our Data Privacy Officer, please write to: Data Protection Officer, Gurtnafleur Road, Clonmel, Co. Tipperary, Ireland, E91 D768. If you believe that the way in which we process your personal data is prohibited, please write to us at Data Protection Officer, Gurtnafleur Road, Clonmel, Co. Tipperary, Ireland E91 D768

You are also entitled to contact the data protection authority. We are regulated by the following data protection authority: Irish Data Protection Commissioner.

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