Updated 11 April 2019.
What do the terms in this Privacy Statement mean?
First, we need to be clear about how we use some words in this statement. It may seem obvious, but in this VISUfarma privacy statement (hereinafter: ‘Statement’) you will be referred to as ‘You’. This Statement applies to all visitors of VISUfarma websites, business partners, customer(s) (contact persons) and supplier(s) (contact persons).
In case you are a VISUfarma employee or a temporary resource, contractor, consultant, agent or similar third party, and you would like to know about personal data being collected by VISUfarma, we would like to refer you to our privacy statement for VISUfarma employees.
When we talk about ‘us’ or the ‘Company’ we mean VISUfarma as a whole or one of the Group companies.Finally, this is a statement about information, about people – like data about you. It’s not about information about VISUfarma or another company (although sometimes the two overlap). We will use the term ‘personal data’ to refer to this information.
What personal data does VISUfarma collect and use?
- Personal data that VISUfarma usually collects includes, but is not limited to:
• your name and contact and communication details;
• personal data on your visits to VISUfarma websites including, but not limited to, traffic data, location data, weblogs, content from surveys and contact forms and other communication data and the resources that you access.
• specifically for customer relationships: name, employer, job title and role, (work) contact and communication details, gender, bank details, purchase history, email correspondence;
• specifically for supplier relationships: name, employer, job title and role, (work) contact and communication details, gender, bank details, purchase history, email correspondence;
• IP addresses and cookies;
o We collect data about your computer, including (where available) your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns, and does not identify you or any individual.
Why do we use your personal data?
VISUfarma collects and processes your personal data:
1) to provide you or the company you are working for with the services you expect us to, like offering you or your employer with requested goods and services;
2) for the purposes of managing our relationships with business partners, customers and suppliers, including communicating with those parties, keeping records of those communications and promoting our products and services;
3) with your consent we may also use your contact data for direct marketing for example via e-mail, messaging or telephone;
4) to transfer data to third parties (see below);
5) where necessary, to comply with any legal obligation;
6) to best tailor content and resources according to your preferences;
7) to respond to your request or questions when you contact us;
8) to ensure that the content provided through the VISUfarma websites is presented in the most effective manner for you and for your device;
9) to further develop and improve the VISUfarma websites and systems to better serve you.
10) we may also process your personal data to:
a. promote the security and protection of people, premises, systems and assets;
b. monitor compliance with internal policies and procedures;
c. administer communications and other systems used by VISUfarma (including internal contact databases);
d. investigate or respond to incidents and complaints;
e. comply with obligations and rights and cooperate with investigations carried out by the police, government or regulators; and
f. participate in any potential or actual purchase or sale, or joint venture, of all or part of a business or company, that any member of VISUfarma wishes to participate in.
What does the law say about this?
We are required by law to have a ground set out in the law to process your personal data. When you are working with VISUfarma, our processing of personal data for all these purposes is based on processing grounds like:
– the performance of a contract to which you or your employer is a party,
– processing necessary to comply with legal or regulatory obligations;
– processing necessary in the legitimate interests of VISUfarma in exercising its and its staff fundamental rights to run a business in a way which does not unduly affect your interests or fundamental rights and freedoms (purposes 1, 3, 4 and 5), and/or;
– in limited circumstances, processed with your consent, which we obtain from you from time to time, such as when you opt-in to receive marketing communications and news via email. When processing is necessary for the legitimate interests of VISUfarma, we ensure that processing is conducted in such a manner that our legitimate interests outweigh any individual’s
interest. We shall only process your personal data other than on these grounds with your consent (a further processing ground).
Do you have to give us the personal data we ask for?
Sometimes providing your personal data is a requirement to enter into a contract with you or your employer and/or to comply with that contract. This means that it is necessary for us to have your data at our disposal. In most cases you are not obliged to provide personal data to us, but it is more or less impossible for us to work with you and provide our services if you do not.
Do we process data about you without any human
intervention at all?
The retention periods of your personal data depend on the respective purpose for which this data is processed. It is not possible to provide an overview of the various retention periods in this privacy statement in a reasonably clear format. The criteria used in determining the applicable retention period are that we will retain the personal data described in this privacy statement for as long as:
(i) it is necessary for the respective purpose,
(ii) it is necessary to conduct our business relationship with you or with your employer,
(iii) you have consented to it and/or
(iv) it is required under the retention rules laid down by law.
Do we transfer your personal data to third parties?
As mentioned above, that it could be possible that we disclose your data to third parties. This is done to complete the purposes set out above. We do this only in the following circumstances:
• To our suppliers.
We may, for example, engage a supplier to carry out administrative and operational work in support of our relationship with you. The supplier(s) will be subject to contractual and other legal obligations to preserve the confidentiality of your data and to respect your privacy, and will only have access to the data they need to perform their functions; these suppliers are typically:
– IT suppliers (who host or support our VISUfarma websites and IT systems, including information about you),
– premises management companies (who look after physical security at our buildings, and therefore need to know about you to allow access to our buildings), back office finance and accounting management providers;
• To members of the VISUfarma group, all located inside the European Economic Area, for necessary intercompany exchange of data;
• We will share your data with government, police, regulators or law enforcement agencies if, at our sole discretion, we consider that we are legally obliged or authorized to do so or it would be prudent to do so;
• As part of due diligence relating to (or implementation of) a merger, acquisition or other business transaction we may need to disclose your data to the prospective seller or buyer and their advisers.
Do we transfer your data outside the European Union?
Normally, we won’t transfer your personal data to a country outside the European Union. In exceptional situations though, your data might be transferred outside the EU. We shall only transfer your data outside the EU to countries which the European Commission believes offers an adequate level of protection to you (a list of those countries is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm), or where VISUfarma has put in place appropriate safeguards to seek to preserve the privacy of your personal data (for which we usually use one of the forms of data transfer contracts approved by the European Commission, copies of which are available here: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm).
What are your rights?
Right to access and obtain a copy of your personal data
You are entitled to request confirmation whether we process any of your personal data. Where this is the case, you may have access to your personal data and to certain information about how it is processed. In some cases, you can ask us to provide you with an electronic copy of your personal data.
Right to correct your personal data
If you can demonstrate that personal data we hold about you is not correct, you can ask that this data is updated or otherwise corrected.
Right to be forgotten/have data deleted
If we do not need to retain or process the data for any other reason, you may request that we stop or restrict the processing or delete (some or all of) your personal data.
Right to object
As far as VISUfarma’s processing of your data is based on its legitimate interest (and no other processing ground) or relates to direct marketing, you are entitled to object to VISUfarma processing your data by reference to your particular situation. To the extent our processing of your personal data is based on your consent, you also have the right to withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of any processing based on your consent before the receipt of such withdrawal. If you want to exercise any of your rights, please email us at [email protected] If you contact us by email to exercise your rights, we may ask you to identify yourself before any action is taken at your request. Finally, you also have the right to submit a complaint to the Dutch data protection authority, that is “De Autoriteit Persoonsgegevens” in The Hague.
How can you contact us?
If you have any questions or concerns regarding this privacy statement or you would like further information about how we protect your personal data (for example when we transfer it outside Europe) and/or when you want to contact VISUfarma’s Privacy Officer, please email us at [email protected].
How do we handle changes to this privacy statement?
The terms of this Statement may change from time to time. In case we publish any material changes to this Statement, we will make sure we contact you via our regular communication channels.
Feedback is a critical element of continual improvement. To provide feedback on this VISUfarma privacy statement, please send an email to [email protected].