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Privacy policy

This Privacy Policy applies to personal data collected through the website www.hra-pharma.com (“Website”).
HRA Pharma, with registered office at 200 avenue de Paris, 92320 Châtillon, Paris, France and registered with the register of legal entities under the SIRET number 420 792 582 00025 (“HRA Pharma”) is the Controller for the processing of your personal data for the purposes described below. HRA Pharma will collect your Personal data in accordance with this Privacy Policy and applicable laws, notably with the General Data Protection Regulation (Regulation (EU) 2016/679).
The following terms “Personal data”, “Processing”, “Controller”, “Processor”, “Data protection authority” take the definitions given by article 4 of the General Data Protection Regulation (Regulation (EU) 2016/679).

1. Which personal data are collected?

HRA Pharma collects Personal data via the Website and the forms available on the Website, which includes:

1.1 Information collected about you when you access this website

These data are collected through the use of the Website and correspond to the following categories:

  • Domain and server (host) from which you access this website on the Internet;
  • Address of the website from which you access our website, only in case of failure;
  • Date, time, length of visits of this website and pages most frequently accessed;
  • Your internet protocol (IP) address;
  • Operating system of your computer and details of your web browser.

1.2    Information collected about you when you choose to complete a form available online

These data are collected through forms available online. Depending on the form, the collected data are:

  • Candidate Form: this form is provided to allow you to submit your CV and your personal information if you would like to work for HRA Pharma. The main categories of personal data processed are the following: your request, notably your surname, first name, email address, country of origin, curriculum vitae (CV), your motivation letter if it was attached, the content of the message you sent us and our answer on whether your application may be suitable for available position.
  • Partnership/Licensing Form: this form is provided to allow you to discuss with us if you have a partnership opportunity. The main categories of personal data processed are the following: your request, notably your surname, first name, email address, job title, phone number, type of partnership, therapeutic area, your partnership proposition, company name, company website, country and our answer. You can also choose to inform us on your company’s address, state, city, code postal/zip code, country, on your mobile phone number and to upload a file of your choice, and our answer.
  • Clinical trials Form: this form is provided to allow you to ask us for further information about HRA Pharma clinical trials. The main categories of personal data processed are the following: your request, notably your surname, first name, institution, qualifications, email address, phone number, country and our answer. You can also choose to inform us on your address, state, city and zip code but it is not mandatory. Regarding the study suggestion/research project, we will collect data on the therapeutic area you chose, your indication, the number of studies already led and the targeted population.
  • Medical information Form: this form is provided to allow you to contact us if you would like assistance and/or an advice on medical questions you may have about our products. The main categories of personal data processed are the following: your request, notably your surname, first name, email address, country, product for which information is requested and our answer.
  • Drug safety contact Form: this form is provided to allow you to report any Adverse Drug Reactions (ADRs) or side effects to your medicine. The main categories of personal data processed are the following: your request, notably information about whether or not you are a health professional, initials, your age, gender, country, email address, HRA product used and the observed adverse reactions and our answer. You can also choose, if you wish, to provide us your surname and first name as well.
  • Media Form: if you are a journalist, this form is provided to allow you to ask questions to our media relations team. The main categories of personal data processed are the following: your request, notably your surname, first name, phone number, email address, company/organization/institution, the content of your message and our answer.
  • Contact form: you can choose to complete this form if you have a suggestion or would like to contact us on a particular subject. The main categories of personal data processed are the following: your request, notably your surname, first name, email address, the content of your message and our answer. You can also choose, if you wish, to select a country.

These forms are at your disposal in case you want to contact us. We would like to remind you that their completion is not mandatory.
HRA Pharma may supplement the personal information it collects with information obtained from other sources (for example, when a health professional calls on behalf of one of his patient to report an adverse drug reaction). HRA Pharma will use any supplemental information in accordance with applicable law (including obtaining your consent where required).

2. What are the purposes for processing and the legal basis?

Your personal data will be processed for the following purposes and in accordance with the legal basis set out below. The table below also provide you with categories of recipients of your personal data.

  Purposes Legal basis Categories of recipients
General Managing and providing the Website (please see our cookie policy) Our legitimate interest to provide a Website IT Services
Communication
Performing statistics on the use of the Website (please see our cookie policy) to improve the quality of our website Your consent
Patients and consumers Managing information received concerning adverse effects Comply with our legal obligations Scientific Affairs Department
Managing and responding to requests concerning medical information Comply with our legal obligations and with our legitimate interest to answer your questions
Health professionals Managing information received concerning adverse effects Comply with our legal obligations Scientific Affairs Department
Managing and responding to requests concerning medical information Comply with our legal obligations
Carrying-out and follow-up information and communication actions for example to invite you to congress, seminars, debates and carry out market research, scientific cooperation or research Our legitimate interest to develop and maintain our relationship with you Marketing services
Communication
Job applicants Processing your online job application and evaluating your suitability for a position at HRA Pharma Our legitimate interest to evaluate your application for a position at HRA Pharma and to take the necessary measures prior to concluding a contract with you HR services and potentially recruitment agencies working for HRA Pharma
Business Partners Analysis of potential partnership and signature of partnerships The development of partnerships Commercial services
Communication
Press Managing and responding to  requests concerning HRA Pharma’s business or products Our legitimate interest to develop and maintain our relationship with you Communication


In addition to the categories of recipients above mentioned, HRA Pharma will transmit your Personal data to our authorized Processors which will process your Personal data on behalf of HRA Pharma. HRA Pharma will also communicate your personal data to relevant authorities as required by applicable laws.

3.    How long will your personal data be retained?

In accordance with applicable data protection legislations, the information collected about you when you access the website will not be retained for more than 3 years.
Regarding your personal information, the retention period is the following:

  • Managing and providing the Website: until 3 years
  • Performing statistics on the use of the Website: until 3 years
  • Managing information received concerning adverse effects: until 10 years after the expiration of the last marketing authorization of the relevant pharmaceutical product
  • Managing and responding to requests concerning medical information: until 10 years after the expiration of the last marketing authorization of the relevant pharmaceutical product in the case the question involves adverse effect
  • Carrying-out and follow-up information and communication actions for example to invite you to congress, seminars, debates and carry out market research, scientific cooperation or research: until 5 years
  • Processing your online job application and evaluating your suitability for a position at HRA Pharma: until 2 years
  • Analysis of potential partnership and signature of partnerships: until 5 years
  • Managing and responding to requests concerning HRA Pharma’s business or products: until 2 years

4.    Transfers outside of the European Economic Area

HRA Pharma may be able to transfer your personal data outside of the European Economic Area. Is that case, processes will comply with Regulation (EU) 2016/679 requirements.

5.    Opportunities to reduce the collected personal data

You can reduce the amount of personal data we collect about you as follows:

  • Limit the amount of personal data you provide HRA Pharma through the Forms to the mandatory fields.
  • Disable the use of tracking technologies: HRA Pharma uses tracking technologies, such as cookies, which can collect personal information about you. You can turn these tracking technologies off. If you want more information, please refer to our cookie policy.

6.    Security

HRA Pharma will implement appropriate technical and organizational measures to ensure an appropriate level of security regarding the risk incurred and protect your personal data against unauthorized access, disclosure, alteration or destruction.

7.    What are your rights? How can you exercise them?

Under applicable Data Protection Law, notably the General Data Protection Regulation (“GDPR”) you have a number of rights with regard to your personal data. Those rights are as follows:

  • Right to Access – You can ask to see the personal information HRA Pharma holds about you. In connection with a request, HRA Pharma may request specific information about you to enable us to confirm your identity and right access, as well as search for and provide you with the personal information HRA Pharma holds about you. In the event we cannot provide you with access to your personal information (for instance, personal information may have been destroyed, erased or made anonymous), we will inform you of the reasons why.
  • Correction or Deletion of Personal Information – HRA Pharma works to ensure that personal information in its possession is accurate, current and complete. If you believe that the personal information HRA Pharma holds on you is incorrect, inaccurate, incomplete or outdated, you may request the revision or correction of that information. If it is determined that personal information is inaccurate, incomplete or outdated, we will revise it.
  • Withdrawal of Consent – If you have provided consent for the processing of your data, you have the right to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.
  • Objection to processing – you have the possibility to object to the processing of your personal data including profiling, on grounds relating to your particular situation as provided by Data Protection law.
    When profiling is related to direct marketing you always have a right to object.
  • Limitation to processing – you have the right to obtain from us restriction of processing in certain instances as provided by data protection law.
  • Right to data portability – you have the right to receive the personal data, which you have provided to us, in a structured, commonly used and machine-readable format when the processing is based on your consent or on a contract. You also have the right to ask us to transmit it to another data controller of your choice.
  • Complaints – You have the right to lodge a complaint to the Data Protection Authority, if you believe that HRA Pharma has not complied with the requirements of the GDPR with regard to your personal data

If you wish to exercise one of these rights, please send a request in this regard via email to dataprivacy@hra-pharma.com or by post to Laboratoire HRA Pharma, 200 avenue de Paris, 92320 Châtillon, France, stating both your name and surname, together with a copy of your identity card.
If you have unresolved concerns you also have the right to complain to the data protection authority in the country where you live or work or place of the alleged infringement.

DPO contact details:
Mr. Christian SOLLET, at:
dataprivacy@hra-pharma.com

or

Laboratoire HRA Pharma
200 avenue de Paris 
92320 Châtillon, France

Effective date: May 25, 2018

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