Privacy Policy

Who is the data controller?

In this Privacy Policy (this “Policy”), “V.J. Salomone Pharma”, “we”, “us” or “our” means V.J. Salomone Pharma Limited, (a company incorporated in Malta, with registration number C-26986, and with principal offices at 79, Simpson Street, Marsa, Malta).

All personal data obtained by us is held and used in compliance with this Policy, with the Maltese Data Protection Act, and the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council (hereafter referred to as the “GDPR”).  V.J. Salomone Pharma Limited is deemed a “data controller” for the purposes of the GDPR.

What is personal data and what are special categories of personal data?

Under the GDPR, personal data consists of any information relating to an identified or identifiable natural person (‘data subject’).

The GDPR provides that special categories of data relates to the “processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”.

What categories of personal data do we collect and how?

In this Policy “you” or “your” means you, the person who provides us with personal data; and, “personal data” shall have the meaning assigned to it by Article 4 of the GDPR.

• Name and surname;
• The Company with whom you are employed (if applicable);
• Email address; and
• Telephone number (fixed and/or mobile).

This information is being requested to enable us to contact you and resolve any queries which you may have.

• Information we obtain

Through cookies and similar technologies we may collect information to recognise you, remember your preferences and tailor the content we provide to you, such as your IP address and your navigation history.  For more information on what Cookies are, and what they do, please refer to our Cookies Policy.

Save for such circumstances described, you may still visit our site anonymously.

What do we use your personal data for and for what lawful reason?

We collect, store and process your personal data to provide you with the best service, and in particular for the following reasons:

• To respond to any queries, comments and/or requests, submitted by you, about our products and services;

Through the “Contact Us” page within our website you may submit queries, comments or requests.  We will collect and process your personal data for the purpose of responding to your queries, comments and/or requests to ensure that we provide you with the best service and to enable us to continue to improve our products and services, as this is in our legitimate interest.

• To defend and protect our legal rights and interests

We may also process your personal data for our legitimate interest to defend or protect our legal rights and interests, as and if required.

Who do we share your personal data with?

We may also share some of your personal data with the following categories of third parties:

• Group undertakings – which provide us with IT support services.

• Third party IT companies – which administer, maintain and support our website and which transmit any personal data submitted in the website to us.

• Legal and other professional advisers and law courts in order to enforce our legal rights, where applicable.

Links to third party websites

Occasionally, at our discretion, we may include links to third party websites. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Security, storage, and transfer of your personal data

We are committed to ensuring that your personal data is secure at all times. We have in place suitable technical and organisational measures to safeguard and secure the personal data we collect, in particular, to protect data against any accidental or unlawful destruction, accidental loss, corruption, unauthorised circulation or access, as well as against any other form of unlawful processing or disclosure to unauthorised persons.

Your personal data will be stored on and processed by our systems and may also be stored on and processed by systems of a third party data processor(s) appointed by us.  Your personal data is not transmitted or stored outside the EU.  All of our employees and third parties, are contractually obliged to respect the confidentiality of your personal data.  We also ensure that sufficient security measures are implemented by such third parties when collecting, storing and/or transmitting data on our behalf.

For how long will we retain your data?

We will keep your personal data only for as long as we need it for the purpose it is being processed for. In setting retention periods we take into account our business and administrative needs to process your data, as well as, our legal obligations to retain your personal data. We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or administrative purpose for it to be retained.

Do we use cookies?

Yes.  Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser, that enables the sites or service providers systems to recognize your browser and capture and remember certain information.

In order to improve our services, to provide you with more relevant content and to ensure analyse how visitors use our website, we may use cookies that in most cases we will not be able to identify you from the information we collect using these technologies.

For further, more detailed information on how we use cookies, please refer to our Cookies Policy.

What are your rights as a data subject?

At any point while we are in possession of, or processing your personal data, you have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have the right to restrict the processing of your personal data.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing.
• Right to withdraw consent – when we process your personal data based on your consent, you have the right to withdraw consent at any time.

Data Protection Officer

We have appointed a Data Protection Officer (hereafter referred to as “DPO”), for the purpose of ensuring compliance with this Policy.

If you wish to exercise any one of your rights or have any questions or concerns about this Policy, you are invited to contact our DPO, via email: [email protected] or by post using the following mailing address:  Data Protection Officer, V.J. Salomone, Upper Cross Road, Marsa, Malta.

We endeavour to process your requests within thirty (30) days from receipt and requests will be processed free of charge, unless requests are deemed excessive or unfounded, in which case we may charge a reasonable fee.

Complaints

In addition to the rights listed above, you also have the right to lodge a complaint to the Malta Office of the Information and Data Protection Commissioner (IDPC) by visiting their website at:  https://idpc.gov.mt, or to the data protection Authority in the country where you reside.

Changes to this Policy

This Policy is effective as of the “Effective Date” listed below.  We reserve the right, at our sole and absolute discretion, to change or modify this Policy at any time. If we decide to change our Privacy Policy, we will update the Privacy Policy modification date below and prompt you to read and accept the changes.

By agreeing to our Privacy Policy you hereby confirm you have read and accept our privacy policy.

This policy was last modified on 20-05-19