Privacy police

DATA PROCESSOR:

Owner: Francesc Arcas Ruscalleda (also the Provider)

Address: Riera Gavarra, 44. Canet de Mar. 08360 Barcelona. 

E-mail: info@iapharm.com

The Provider, as the Data Processor for the Website and in accordance with the provisions of Regulation (EU) 2016/679 of 27 April 2016 (GDPR), Constitutional Act 3/2018 of 5 December (LOPDGDD), and other legal regulations in force on the protection of personal data, and with the Information Society Services and e-Commerce Law 34/2002 of 11 July (LSSICE), informs you that we have implemented the necessary security, technical and organizational measures to guarantee and protect the confidentiality, integrity and availability of all data entered.

1. BACKGROUND

This privacy notice sets out the basis on which any Personal Data we collect from or about you, or that you provide to us, including through www.iapharm.com and any sub-domain thereof (“our website”), will be processed by us in accordance with applicable Data Protection Laws. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.

Our website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

2. PLATFORM USERS

If an organization with which you are associated (an “Organization”) signs up to use our Platform, we may receive Personal Data about you in connection with our provision of the Platform to your Organization. To the extent we process that Personal Data solely in order to provide the Platform to your Organization, under the GDPR, to the extent applicable, we will act as a processor (as defined in the GDPR) on behalf of your Organization in respect of that Personal Data; this privacy notice will not apply to the processing of that Personal Data and your Organization will act as a controller (as defined in the GDPR) in respect of that Personal Data and is responsible for obtaining all necessary consents and providing you with all requisite information as required by Applicable Law. To the extent we process your Personal Data for any other lawful business purpose of ours, under the GDPR, to the extent applicable, we will act as a controller of such Personal Data and this privacy notice will apply to the processing of such Personal Data. For clarification but not limitation, information we process for our legitimate business purposes, such as product development, sales and marketing, is not processed solely on behalf of your Organization.

3.  DATA PROTECTION RIGHTS

Users can request the following rights:

Right to request access to personal data.

Right to request rectification if the data is inaccurate, or to complete any data that is incomplete.

Right to request deletion of your data.

Right to request the restriction of processing of your personal data: in this case we will only retain it to exercise or defend claims.

Right to object to processing: Provider will stop processing personal data, except when it must continue to be processed for legitimate reasons or for the exercise or defence of possible claims.

Right to data portability: in the event that users wish their data to be processed by another data controller, the Provider will facilitate the transfer of their data to the new controller.

Right not to be subject to a decision based solely on the automated processing of your personal data

If you have given your consent for a specific purpose, you may withdraw it at any time, without this affecting the lawfulness of the processing based on your prior consent to its withdrawal.

As soon as users exercise their rights of deletion, all personal data linked to their account will in any case be cancelled, as well as the information and contents that are included in their profile. Furthermore, in the event that the user exercises the right to delete the data necessary for the Provider to provide the website services, the Provider will be obliged to terminate its relationship with the user by cancelling their registration, without them having any right to complain.

To exercise their rights, users must send a written communication to the Provider registered offices or to the email address indicated in section 1 of this Privacy Policy, including photocopies of their ID card or any other equivalent identification document in both cases.

4. KIND OF DATA COLLECTED

Based on this Privacy Policy, “personal data” means any information that identifies you or can be used to identify you, such as your name, address, telephone number or email address.

If you decide to provide us with your personal data, The Provider may have access to the following:

1. Personal data provided voluntarily by the user:

First name and surnames.

ID/Tax ID/Foreign National ID

Postal Address.

Telephone number.

Country of origin.

User profile.

This data is processed when you interact with Iapharm and our representatives; when you participate or ask to be considered to participate in activities related to iapharm, such as the provision of online services or surveys about our services or activities; when you interact with the website when you are asked to provide personal data, as described in this Privacy Policy and Cookies Policy; when you register on our website or use certain features without registering, such as participating in our interactive services.

b) Personal data that our website obtains from your computer or electronic device:

• Cookies, only for https://www.iapharm.com

For more information on the use of cookies by Iapharm, please consult our Cookies Policy.

5. DATA PROCESS

The provider may process your personal data on the basis of any of the following legal grounds: (A) legitimate business purposes; (B) when you have given your consent; (C) when necessary to comply with the legal and regulatory obligations of the provider and (D) as necessary for the performance of a contract to which you are party.

6. DATA ACCES

Depending on the purposes for which personal information is collected, it may be accessed by any of the following people:

• Authorized Iapharm staff or their representatives acting on behalf of Iapharm, subject to the applicable data protection laws;
• Regulatory authorities or other third parties in accordance with applicable laws;
• Third party service providers that process information as data processors, according to the instructions of Iapharm. This is only after taking the necessary steps to ensure that we can share such information in compliance with applicable data protection laws.

We will not sell or disclose any personal information or data to third parties that you have provided on our website and that may identify you directly or indirectly.

7. STORAGE OF PERSONAL DATA

7.1 Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Data transmitted through out website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

7.2 Our external third-party providers may be based outside the European Economic Area (EEA) so their processing of your Personal Data will involve a transfer of Data outside the EEA.

7.3 Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it. Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EEA under the GDPR. If we rely on another basis to transfer your Personal Data outside of the EEA (such as your consent), we will keep you updated or contact you as required.

7.4 Please contact us if you want further information on the specific mechanisms used by us when transferring your Personal Data out of the EEA.

8. THIRD PARTY LINKS

Our website, from time to time, may contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.

9. DATA SECURITY

9.1 We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.

9.2 We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. DATA RETENTION

10.1 We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

10.2 To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

11. YOUR RIGHTS

Under certain circumstances and in compliance with the GDPR, you may have the right to:

11.1 Request access to your Personal Data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it. You will usually not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.11.2 Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate Personal Data we hold about you corrected, though we may need to verify the accuracy of the new Personal Data you provide to us.

11.3 Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

11.4 Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

11.5 Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the Personal Data’s accuracy; (b) where our use of the Personal Data is unlawful but you do not want us to erase it; (c) where you need us to hold the Personal Data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your Personal Data but we need to verify whether we have overriding legitimate grounds to use it.

11.6 Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

12. HOW TO EXERCISE YOUR RIGHTS

In order to exercise any of your rights please contact us using the contact details provided in section 21 of this notice.

13. WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

14. TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

15. RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

If you have any complaints about the way in which we process your Personal Data please do contact us, as set out below in Section 21. Alternatively, you have the right to lodge a formal complaint with your data protection supervisory authority.

16. CHANGE OF PURPOSE

16.1 We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us in the manner described in Section 21.

16.2 If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

16.3 Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

17. DO NOT TRACK

The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided in Section 19 below.

18. CHANGES TO OUR PRIVACY NOTICE

Any changes we make to our privacy notice in the future will be posted to this section of our website and, where appropriate, notified to you by e-mail. We will not make changes that result in significant additional uses or disclosures of your personally identifiable information without allowing you to ‘opt in’ to such changes. We may also make non-significant changes to this privacy notice that generally will not significantly affect our use of your personally identifiable information, for which your opt-in is not required. Please check back frequently to see any updates or changes to our privacy notice.

19. CONTACT US

General questions, comments and requests regarding this privacy notice are welcomed and should be addressed to our compliance team using the following email address: arcasruscalleda@gmail.com.

Last updated on Frebuary 1, 2020.