GJK HealthPharma Services Ltd (hereinafter HealthPharma) is committed to protecting your privacy as one of our clients, prospective clients, suppliers, job applicants and visitors to our website www.healthpharma.eu or our webshop www.healthpharma.eu/shop (the Website) and is committed to inform you on how we gather and use your personal data.
Please read our Privacy Policy to understand how we collect and use your Personal Data and the rights you have in relation to your Personal Data.
Our Website may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other websites. This privacy policy applies solely to information collected on our Website. Please note that we may change our Privacy Policy from time to time. If we make any changes, these will be shown on our Website and will immediately supersede any previously posted information.
Your use of the Website following these changes means that you accept the revises Privacy Policy.
We encourage you to read this Policy at regular intervals to know how your Personal Data is protected.
1. Who is responsible for Personal Data?
HealthPharma is responsible for all Personal Data it processes about its clients, prospective clients, suppliers, job applicants and Website visitors. HealthPharma is a registered office at 2 Sofouli Street, Chianteclair Bldg. Office 503-505, 5th Floor, 1096 Nicosia, Cyprus with company registration number HE44332. You can contact us via our details in Section 12.
2. What Personal Data do we process?
The Personal Data we collect and process about you will differ depending upon our relationship. We will process and hold different Personal Data if you are a client, a prospective client, a supplier, an applicant or a visitor to our Website. This is the Personal Data we process depending on your relationship with HealthPharma:
Clients:
- contact details (such as first name, last name, address, telephone, email)
- personal characteristics (such as gender)
- professional information (such as company, title /function, department, website)
- areas of professional interest
- activities and events
- information about the services we provide
- financial information and account details (such as VAT-number, bank account number, account details, credit history, credit reference information, and other financial information)
- photographs and video recordings at events
- marketing preferences, marketing activities, and client feedback
Prospective clients:
- contact details (such as first name, last name, address, telephone, email address)
- professional information (such as company, title/function, department, website), VAT number
Suppliers
- contact details (such as first name, last name, address, telephone, email address)
- professional information (such as company, title /function, department, website)
- financial information and account details (such as VAT-number, bank account number, account details, credit history, credit reference information and other financial information)
- information enabling us to receive products and/or services from you
- online activity information (such as information from your use of our Website)
- additional information from other sources (such as from publicly available information sources, from credit rating agencies)
Job applicants
- contact details (such as first name, last name, address, telephone, email address)
- personal details (such as your date of birth)
- information about the position you are applying for
- language skills
- education and training
- curriculum vitae
- motivation
Job applicants
When using our Website, you are not obliged to provide us with any Personal Data. Check our cookie policy to see how you can switch off tracking cookies when browsing. However, to use some of the functionalities on our website, you will be asked to share some Personal Data.
- Contact (form). If you contact us via our Website, we will collect and hold your contact details (such as first name, last name and email address, IP address).
- Newsletter Subscription. If you subscribe to our newsletters, we will collect and hold your contact details (such as your first
name, last name, job title, email address, postal code, country, your IP address and language
preferences) - Event Registration or Competitions. If you register for any of the events we are organizing (such as open door events, trainings) or competitions, we will collect and hold your contact details (such as your first name, last name, job title, telephone, email address, postal code, country, your IP address and language preferences).
- Job Applicants. If you apply for a position at HealthPharma, we will collect and hold your contact details (such as first name, last name, address, telephone, email address), personal details (such as your date of birth), information about the position you are applying for, language skills, education and training, curriculum vitae and motivation.
When you browse our Website, certain user and device data may be collected. This information will never reveal your personal identity and therefore isn’t concerned as Personal Data. To be able to track this type of data, our Website makes use of cookies. You can find our cookie policy right here: https://healthpharma.eu/cookie-policy/ What is user and device data? Internet browser and electronic device information, information collected through cookies, pixel tags and other technologies, demographic information, and aggregated data (i.e., data grouped together so that it is not possible to link the data to a particular individual). We and our third-party service providers may collect user and device data in a variety of ways when you use our Website, including through your internet browser or electronic device. This type of data collection can be switched off via your browser.
Find out here https://healthpharma.eu/cookie-policy/ how you can do this if you don’t want us to collect this type of data.
4. For what purposes do we use Personal Data?
The purposes of processing your Personal Data will be different depending on our relationship.
Clients
- to communicate with you
- to sell and deliver our products and services
- to carry out client-relationship management
- to improve the quality of our services
- to carry out research and analysis
- to provide marketing information
- to ensure the security of our premises and facilities
- to manage our business operations and IT infrastructure
- to manage complaints, feedback and queries
- to comply with applicable laws and regulatory obligations
Prospective clients
- to communicate with you
- to carry out prospective client-relationship management
- to carry out research and analysis
- to provide information on products and services
- to ensure the security of our premises and facilities
Suppliers
- to communicate with you
- to carry out supplier management
- to ensure the security of our premises and facilities
- to manage our business operations and IT infrastructure
- to manage complaints, feedback and queries in the framework of our procurement activities
- to comply with applicable laws and regulatory obligations
Job applicants
- to communicate with you
- to carry out recruitment and selection activities
- to evaluate applications
- to assess your eligibility and suitability for a position
- to possibly offer you employment
- to take pre-contractual measures prior to your employment as an employee
- to build a recruitment pool
As a prospective client, you are not obliged to provide any Personal Data to us. If you are a client or a supplier, the provision of certain Personal Data is a statutory or contractual requirement (e.g., we need certain Personal Data of clients in order to document our engagement, for billing purposes). If you are a job applicant, the provision of certain Personal Data is a requirement necessary to entering into a possible contract.
5. What are the legal grounds for our use of Personal Data?
Applicable data-protection legislation requires us to be transparent about the legal grounds or justification for the processing of Personal Data. We generally rely on the following legal grounds for the processing of Personal Data.
- Your consent. In many cases, your Personal Data will be processed by HealthPharma on the basis of your consent. For example, we may ask your consent to process your data in order to provide you with marketing information and product updates. We may seek your consent in writing or electronically. When seeking your consent, we will inform you about how your data will be used, as well as the purposes. In some circumstances, such as telephone conversations, consent can be given verbally. When you have provided your consent, you can withdraw it at any time.
- Necessary for the performance of a contract. Personal Data of clients may be processed by us in order to establish, perform and terminate a contract (e.g., for the provision of our services). Prior to a contract – during the contract initiation phase – Personal Data may be processed to prepare bids, pitches or purchase orders or to fulfil other requests of the prospective client that relate to contract conclusion. Prospective clients can be contacted during the contract preparation process using the information that they have provided.
- Legal obligations to which we are subject. In some cases, we may need to process your Personal Data because applicable laws or regulations require, request or allow it, for example to prevent, detect and investigate fraud or crime or to comply with specific tax obligations.
- Our legitimate interests. In many cases, we process your Personal Data because we have a legitimate business interest in doing so. This is the case, for example, when processing your Personal Data to communicate with you, to improve the quality of our services, to provide you with marketing information (incl. direct marketing) and to manage our business operations and IT infrastructure. Depending on the specific processing, HealthPharma’s legitimate interests will in general consist of (i) the pursuit of our business activities and commercial objectives; (ii) the protection of our business, partners, shareholders and clients; (iii) the improvement or further development of our services and our business operations in general; (iv) the compliance with legal and regulatory obligations, standards, guidelines and codes of conduct and/or (v) the maintenance
and improvement of our position on the market.
The legal basis for our processing of Personal Data will be different depending upon our relationship.
Clients
- Necessary for the performance of a contract
- Legal obligations to which we are subject
- Your consent
- Our legitimate interests
Prospective clients
- Your consent
- Our legitimate interests
Suppliers
- Necessary for the performance of a contract
- Legal obligations to which we are subject
- Your consent
- Our legitimate interests
Job applicants
- Necessary for the performance of a contract
- Your consent
- Our legitimate interests
6. Where do we process Personal Data?
In principle, your Personal Data will be kept in Cyprus or in another country within the European Economic Area. Your personal data will not be transferred to, or processed in, any country outside the European Economic Area without you being informed that the transfer can take place legally and securely.
7. How do we protect Personal Data?
HealthPharma has in place appropriate technical and organizational measures to prevent or act against any unauthorized and unlawful processing or disclosure, as well as accidental loss, modification or destruction of Personal Data. Before the introduction of new methods of data processing, particularly new IT systems, technical and organizational measures to protect Personal Data will be defined and implemented by HealthPharma. These measures will be based on the state of the art, the risks of processing, and the need to protect the Personal Data. Furthermore, these technical and organizational measures for protecting Personal Data will regularly be adjusted to the technical developments and organizational changes.
8. How long do we keep Personal Data?
We will keep your Personal Data no longer than necessary for the purposes for which we collected the data. This period is different for each purpose. In addition, there are laws and regulations that apply, and which set minimum and maximum periods for retention of Personal Data.
9. Who may Personal Data be shared with?
In connection with the purposes described in Section 4, we may need to share your Personal Data with third parties, so-called ‘recipients’. These third parties (recipients) may include:
- external third-party service providers (e.g., accountants, auditors, lawyers and other professional advisors; call-center service providers; IT systems, hosting service providers; banks and financial institutions; outsourced service providers that assist us in carrying out our business activities);
- Affiliates that provide you with links to visit our Website and subsequently you proceed to purchase our products (become a client);
- government authorities;
- other third parties (e.g., credit-rating agencies, commercial-information providers, purchasers and prospective purchasers).
10. What rights do you have as a Data Subject?
As a Data Subject, you enjoy the following rights regarding your own Personal Data:
- Right of access. You have the right to obtain confirmation about whether or not your Personal Data is being processed and, if so, to obtain access to your Personal Data and information regarding the processing.
- Right to rectification. You have the right to correct incorrect Personal Data, complete your Personal Data and have recipients to whom Personal Data was provided informed of the rectification.
- Right to erasure. Subject to certain conditions, you have the right to have your Personal Data erased. If your Personal Data was made public, HealthPharma will take reasonable steps to inform the controllers who are processing the Personal Data of your request to erase it and to inform the recipients of Personal Data of your request to erase it.
- Right to restriction of processing. Subject to certain conditions, you have the right to obtain restriction of the processing of your Personal Data, and, in case of restriction, have the processing limited to mere storage.
- Right to data portability. Subject to certain conditions, you have the right to be provided with your Personal Data, which you can reuse as you wish. If you so request, HealthPharma has the obligation to transfer your Personal Data directly to another controller.
- Right to object. You have the right to object to the processing of your Personal Data based on certain grounds and the right at all times to object to the use of your Personal Data for direct marketing purposes.
- Right to withdraw consent. If you have given your consent to our processing of your Personal Data, you have the right to withdraw that consent at any time, without such withdrawal affecting the lawfulness of processing based on consent before its withdrawal.
- Automated individual decision-making, including profiling. In the case of automated individual decision-making, you have the right to obtain human intervention, give your point of view, receive an explanation for the automated decision, and challenge that decision.
- Right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with a supervisory authority. In Cyprus, the Data Protection Officer (DPO) of the Commissioner’s Office can be contacted by regular mail at postal address P.O.BOX. 23378, 1682 Nicosia, or by email commissioner@dataprotection.gov.cy, if you believe that the processing of your Personal Data violates the applicable national and regulatory framework law for the protection of personal data
11. How to change your marketing preferences?
You can decide to change your marketing preferences at any time. If you are a past or current client, we may use your contact details, including your email address, to send you marketing communications. You can at any time and free of charge opt out of receiving marketing communications by unsubscribing in the email or by contacting us (see Section 12).
If you are not a past or current client, we may use your contact details, including your email address, to send you marketing communications, provided you have given your consent. Marketing communications used by HealthPharma may include the following: (i) receiving e-mail messages from us; (ii) receiving telephone communications and postal or electronic mail from us;
12. Who to contact about your Personal Data?
If you have any questions, concerns or complaints about the manner in which your Personal Data is used by GJK HealthPharma Services Ltd, you can contact us by email or regular mail using the contact details below:
- email: info@healthpharma.eu
- regular mail: P.O.BOX 22387, 1521 Nicosia, Cyprus.
This Privacy Policy was last modified on the 10th of February, 2021.