Last update: 25 May 2018
The company “MINERVA Pharmaceutical S.A.” (controller for the processing of your personal data), having its registered office in Peristeri of Attica, 132 Kifissou Avenue (hereinafter the “Company”) undertakes to protect the personal data of visitors of its website. Please read the below policy so as to understand how we collect and use your personal data and the rights you have in relation to the processing of your personal data by the Company. Please be advised that the Company has the right to amend this policy, so please refer to this policy regularly for any changes.1. What kind of personal data do we collect about you?
You do need to disclose any personal information in order to browse our website. Nevertheless, if you have chosen to subscribe to our Newsletter or if you have decided to contact us by submitting an email to the address stated in our webpage, we will collect the following personal data about you:
(α) Contact with us
Our website provides you with the possibility to contact us by sending us an email to the address mentioned therein. In case you contact us in this manner, we will collect your email address, your full name, the subject and the main body of your email, and optionally your telephone number.2. How do we intend to use your personal data and to what end?
Provided you have contacted us about any subject, we will process the data you will send us to contact you and manage any request, report, information or query you may have. In this case, the legal basis for processing your data will be by default compliance with legislation, execution of a contract between us and our ultimate legitimate interest lies in the proper management of requests, reports, information and queries by the users of our preparations, health care professionals, and in general the public in connection with the preparations we manufacture and/or distribute to the Greek market.
What are cookies and what purposes do they serve?
Cookies are small files, which contain information, and are stored in any device (computer, laptop, tablet, mobile phone) that has internet access when you visit our website. Most cookies are used in order to improve usability and functionality of websites, remember our selections and preferences (e.g. selection of operating language), as well as for purposes of website improvement.4. Who has access to your personal data?
Your declared personal data are processed only by the competent staff of our Company. Also, your personal data is accessed by companies that provide us with IT services, cloud computing services, and hosting services, companies which have access to our IT systems and electronic databases, other companies within the Galenica Group that provide us with support, as well as advertising companies, which take on the promotion of our products through the Newsletter service. These collaborators undertake to process your personal data taking strict measures of security, always in accordance with our instructions, and never to use your data for their own benefit.5. How long do we keep your personal data for?
Regarding the personal data you send us when contacting us, we will keep such data for as long as it is required for the management of the request, report, information or query, depending on the purpose and nature of any communication.6. How do we protect your data?
The security of your personal data is of paramount importance to us. We undertake to take strict technical measures, physical and organisational measures and procedures for the protection of your personal data and to impose on third parties collaborating with us that have access to your data the obligation to also take such measures.7. What are your rights?
You may request access to your personal data kept by us, their correction if inaccurate, and their deletion, in accordance with the terms and conditions prescribed by the applicable legislation. You also have the right to be given your data in a structured, commonly used and machine-readable format, and to request their transfer to third parties, to object to the processing of your data and to request its limitation.
Finally, if you deem that the Company is in breach of the applicable legislation on personal data processing, you may submit a complaint before the Personal Data Protection Authority.8. Contact details
To exercise your rights and pose any question regarding processing of your personal data by our Company, you may contact the Company’s Data Protection Officer, in the following ways:– By sending a letter to the following address:
FAO Data Protection Officer
MINERVA PHARMACEUTICAL S.A.
132 Kifissou Avenue
– By calling the following number:
– By sending an email to the following address:firstname.lastname@example.org
Information for patients, consumers, HCPs, and third parties, concerning processing of your personal data in the context of reporting adverse events and filing quality complaints
The company MINERVA PHARMACEUTICAL S.A. (hereinafter the “Company”) collects, records and processes certain personal data declared to the Company by patients, consumers, health care professionals and third parties, in the context of reporting adverse effects and filing quality complaints.
The purpose of this information is to inform the above persons of the processing of their personal data by the Company for the management of adverse effect reports and quality complaints concerning medicines, cosmetics and other preparations manufactured and/or placed on the Greek market by the Company.
1. What categories of personal data do we collect and record on our files?;
The categories of personal data we collect about the users of our preparations (patients and consumers), who develop an adverse effect or are faced with a problem concerning the quality of our preparations (irrespective of whether this adverse effect is reported by them or whether the report is made by health care professionals) are those required by the legislation on medicines and the relevant regulatory framework; they mostly are as follows:
(α) initials or code number of patient, sex, date of birth or age group, sex, age);
(β) information about medication or use of the Company’s preparations;
(γ) description of an adverse event and/or quality issue of the preparation and its outcome; and
(δ) in case of an adverse effect, the relevant medical history of the patient.
Notwithstanding the above, the Company may record the full name of a patient/consumer and other identification details (for example, contact details) only when deemed necessary for the completion of the monitoring of the course of patient/consumer and in general of the case (follow-up).
The categories of personal data collected and recorded by the Company about health care professionals (doctors, pharmacists, etc) that declare an adverse effect or file a quality complaint is the full name, the capacity and their contact details (telephone and/or email).
2. What are the purposes and legal bases for processing?
We collect, process and store the personal data of users (patients and consumers) of the Company’s preparations and of health care professionals that declare an adverse effect or a quality complaint for the purpose of our compliance with legislation on medicines and the relevant regulatory framework concerning pharmacovigilance and quality assurance of medicines, cosmetics and other preparations that the Company manufactures and/or places on the Greek market.
The legal bases for processing of the above personal data is our compliance with obligations arising from legislative and regulatory framework concerning medicines, cosmetics and other similar preparations, as well as ensuring high standards of quality and safety on our medicines and other products.
3. Who are the personal data disclosed to?
In principle, your personal data are not disclosed to third parties. As an exception, your data may be disclosed to third parties (such as, for example, providers of pharmacovigilance services) that help us to record and assess reports of adverse effects and provide us with services; such parties undertake to process your personal data solely on account of and based on our recorded orders and not for their own benefit.
Moreover, as required by relevant legislation, we disclose anonymous or anonymised details concerning the adverse effect to the competent authorities (for example the National and European Organisation for Medicines and the European database Eudravigilance), as well before foreign Marketing Authorisation Holders, for whom we have exclusive distribution rights in the Greek market.
4. How do we process the personal data and how long is it kept for?
We take every measure necessary so as to safeguard security, integrity and confidentiality of personal data.
Typically, physical and electronic files of adverse effect reports and quality complaints are kept for a period of six (6) months from initial entry. By way of exception, identification details of patients/consumers (e.g. full name and contact details) are kept only for such period as required for the follow-up of the consumer/patient and the completion of the case and the taking of all necessary details for the exact recording of the adverse effect and/or quality complaint.
5. Your rights
Any patient, consumer, healthcare professional and third party filing an adverse effect report or quality complaint may request from the Company access, rectification and, in certain cases, erasure of their personal data. Such persons also have the right to restriction of processing of their personal data. These rights may be exercised by sending a relevant letter or an email to the Company’s Data Protection Officer to the address stated below.
Furthermore, the legislation grants the above persons the right to bring actions before the Personal Data Protection Authority.
6. Contact details of Data Protection Officer
For any question or query or in case you wish to exercise any of the rights provided for by the legislation, you may contact the Company’s Data Protection Officer as follows:
MINERVA PHARMACEUTICAL S.A.
132 Kifissou Avenue