We value your trust.
Medochemie Limited (‘Medochemie Limited‘) is a legal entity with Registration No.HE7761, which is engaged in the production, sale and distribution of medicines and/or medicinal and/or pharmaceutical products.
Medochemie Bohemia, spol. s r.o. (hereinafter referred to as “Medochemie”), IN: 251 25 559, with its registered office at Vyskočilova 1566, Michle, 140 00 Prague 4, registered in the Commercial Register at the Municipal Court in Prague, Section C, Insert 51837, is part of the worldwide MEDOCHEMIE LIMITED group operates this website and is also a data controller for the purposes of processing below.
At Medochemie we fully understand the importance of protection and privacy of personal data for all persons Medochemie has dealings with and the need to comply with effective legislation, including the General Data Protection Regulation (‘GDPR‘) or the Personal Data Processing Act and keeps you informed about:
- what personal information we collect about you;
- how we use your personal information;
- on what basis we use your personal information;
- how long we keep your personal information for;
- when, how and why we may share your personal information with others and/or transfer it internationally;
- how we protect your personal information;
- your rights regarding your personal information;
- what to do if you do not want to provide us with your personal information; and
- how we use cookies and where to find further information
- contact details of the controller and data protection officer;
- general principles of personal data processing;
- how, why, to what extent and for how long we use your personal data;
- method of data storage of information collected on minors under the age of 15;
- recipients and processors;
- website server;
- how to access your data and other rights to manage it;
- legal reasons for processing your personal data;
- cookies;
- changes to our Privacy and Cookies Policy.
If however, you still have any questions in relation to our Privacy and Cookies Policy, you can contact us by:
by e-mail: dpo@medochemie.com
by phone: 00357 25 867600
Contact details of the controller and data protection officer
If you have any further questions about our Privacy and Cookies Policy, you can contact us:
- by phone at: +420 241 029 000;
- via e-mail at: czech@medochemie.com;
- in writing at: Medochemie Bohemia, spol. s r.o., Vyskočilova 1566, Michle, 140 00 Praha 4, Czech Republic.
- The contact details of the group data protection officer are as follows:
- name and surname: Giota Andreou;
- e-mail: dpo@medochemie.com;
- telephone number: +357 25 867600;
- address: Medochemie Ltd., established 1-10 Constantinoupoleos Street, P.O. Box 51409, Limassol 3505, Cyprus
General principles of personal data processing
Medochemie, in accordance to the eight privacy principles for GDPR compliance, when collecting, processing and managing personal information, is committed that the data:
- shall be processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
- shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’). Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes;
- shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
- shall be accurate and, where necessary, kept up to date (‘accuracy’). Every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are collected and/or are being processed, are erased or rectified without delay;
- shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’). Personal data may be kept for a longer period only if they are processed for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes in accordance with Article 89 (1), subject to the implementation of the relevant technical and organizational measures required by this regulation in order to protect the rights and freedoms of the data subject.
- shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).
- shall be transferred for processing to a third country or an international organisation only if the conditions laid down in Medochemie’s Privacy and Cookies Policy or Binding Corporate Rules (hereinafter referred to as “BCR”) are complied with by the controller and the processor (‘transfer‘).
- maintained by Medochemie on its own responsibility and Medochemie as the controller shall be responsible for and be able to demonstrate compliance with the GDPR (‘accountability‘).
This Privacy and Cookie Policy applies only to the Medochemie main website www.medochemie.com and country websites of Medochemie and not to any various separate websites that you may be diverted.
By using www.medochemie.com and/or submitting any personal information to us, you agree to our use of your personal information in accordance with the provisions of this Privacy and Cookie Policy.
This Privacy and Cookie Policy applies only to information obtained by us and not to information obtained and/or shared by you with third Parties.
How, why, to what extent and for how long we use your personal data Medochemie has set the following processing purposes in particular:
- Job application
- Contact us - general questions form
- Pharmacovigilance
- Publicly accessible professional information service
- Consumer competitions
- Contact database for sending news
- The legitimate interest of the controller in the protection of his own rights and defense in proceedings
Legal Basis for processing your personal data
Medochemie gathers and processes your personal data only in accordance and within the lawful basis provided in the GDPR as these are applicable in each case:
Consent
The processing of your personal data is rightful if it follows your unequivocal and express consent and for the purposes for which your data is collected. Your consent can be taken either in writing or electronically.
For the performance of a contract
Data processing is permitted if it is necessary for the performance of a contract to which you, as a data subject, are a party, or for taking steps at your demand, prior to entering into a contract, including but not limited to the case of an electronic employment application.
For compliance with legal obligations of Medochemie
Personal data can be processed for the purposes of complying with national and/or European and/or international laws and/or Regulations and only to the extent that such processing is necessary and within the restrictions provided in the said norms.
For protection of the vital interests of the Data Subject and/or any affected third parties
As in the course of our business Medochemie deals with medicinal and/or medical and/or bi-products and/or pharmaceutical products and/or otherwise, processing of your personal data may be necessary for ensuring your health and safety and/or the health and safety of others. Thus, Medochemie has the right to process your data only to the extent that is indispensable for ensuring the protection of your vital interests.
For the purposes of the legitimate interests of Medochemie
Data processing is justifiable if it is necessary for Medochemie to pursue a legitimate interest, provided that it will not override the fundamental rights of data subject.
PRIVACY
Information Collection and Use
While using our website, we may ask you to provide us with certain personally identifiable information that can be used to contact you or to identify you. Personally identifiable information may include, but not be limited to, your name, surname, date of birth, address.
As part of completing an online application and/or the contact forms available on our website, all data shared with us shall be stored on our website which is hosted by Microsoft Inc. Also, all the shared data shall be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP) by SendGrid Services.
We are assured that all steps necessary were taken by the intermediary data controllers in order for them to fully comply with the provisions of the European and Local legislation relating to the protection of personal data.
Recrutiment
1) Application form
In the event that you choose to use our application for employment feature of the website, we will ask you to provide us with personal data including, but not limited to, your name, address, telephone number and ID number. Further we will ask you to upload a copy of your CV.
This information shall be sent to our host servers (which are hosted by Microsoft Inc.) and shall then be transmitted to the appropriate department of Medochemie, as further described above, responsible for the processing of the information provided. This is usually the Human Resource Department of Medochemie, but this may vary.
Our Human Resources Department or the appropriate department of Medochemie shall receive and review the information shared with them by email and shall store all such information locally on their computers which we take all reasonable steps to ensure that are protected. Our SMTP server communication is protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using a cipher before being sent across the internet.
If hard copies of the said information are made, such shall be kept in files located in the Human Resources Department with access only from the members of the Department, the Management of the Company or individuals who may be authorised to have access to such information.
We shall internally process the information shared with us in order to determine your suitability for the position you have applied. Use of such information will be made in the event that we wish to contact you in relation to your application.
2) Direct tender / personal agencies
We shall not use, sell or otherwise make available or distribute such information to third parties and/or entities outside of the Medochemie group of Companies.
The purpose of processing is to ensure a selection procedure, the selection of a suitable candidate for the conclusion of an employment contract for a given job position.
The personal data of the job seeker are processed to the following extent: name, surname, title, private telephone, private e-mail, CV, references and any other personal data contained in the text of the report necessary for the evaluation of work experience.
The personal data of the candidates who send the CV to the controller by e-mail or form are processed for the duration of the selection procedure for the purpose of fulfilling the contract.
In addition, if the candidate consents to the processing of personal data after the selection procedure, his / her personal data are processed indefinitely in order to send suitable new job offers, based on the candidate's consent (legal basis), until the consent is revoked, which may be revoked at any time.
The personal data of the three best candidates who were not accepted are kept for another 3 months after the end of the selection procedure due to the legitimate interest of the controller in any further selection of the candidate at the end of the previous candidate's employment during the probationary period.
Legal bases for this purpose are performance of the contract, consent and legitimate interest. The legitimate interest is explained in these principles.
Contact Us – General Contact Form
Should you wish to contact us using the contact form on our “ Contact Us” page, the data that you supply will be stored by this website hosted by Microsoft Inc. Subsequently the data will be transmitted to the Central Desk as further described above, and shall subsequently be distributed to the appropriate department or individual. Personal information therein included shall be stored on our servers for a period of six (6) months, from the date of submission and shall subsequently be deleted.
If you send us a message via the contact form on the website, your personal data will be processed in order to answer the question or process the request.
Personal data is processed for this purpose to the following extent: name, surname, e-mail and any other personal data contained in the text of the message.
In the event that there is a legitimate interest in their retention for a longer period (for example, for the purposes of control by the supervisory authority), the personal data of the subject will be kept to the necessary extent for another 3 years for the legitimate interest of the controller according to these principles.
The legal base of the processing is consent, without its provision it is not possible to process the question / request, whereas the consent can be revoked at any time.
Pharmacovigilance
Please note that Medochemie registers information about the reported product complaints and suspected side effects for the sake of patient safety and order to comply with relevant and applicable laws and/or European and/or International Regulations and/or directives and/or obligations deriving from and/or relating to the scope of works of Medochemie and/or requested by the relevant local, European and International agencies.
If you are a patient reporting adverse event, Medochemie may obtain sensitive personal data about you, including details about your physical or mental health, as part of the reporting process and tracking the side effects case you reported. Such information (including sensitive personal data) will be provided by you and is used by us in accordance with applicable regulatory requirements to ensure high standards of quality and safety of health care and of medical products or devices and in particular to support Medochemie’s legal and regulatory obligations around reporting side effects associated with its products.
If the controller receives information relevant to the safety of the medicinal product from a person other than the patient, the personal data of the notifier will be processed due to the necessary follow-up communication for the purpose of examining the relevant information.
The personal data of a non-patient whistleblower are processed to the following extent: name or initials, or address or qualifications.
The patient's personal data is processed to the following extent: initials or patient number, date of birth (or age or age category if date of birth is not available), gender and any other relevant documentation.
Personal data of the author of a literary article are processed to the following extent: name, workplace address, e-mail, phone number.
Personal data are processed for a period of 10 years from the end of the registration of the product.
The legal basis of the processing is the fulfillment of a legal obligation.
The recipient of personal data is to a limited extent (according to the report to the supervisory authority) MEDOCHEMIE LIMITED in order to ensure the concentration of pharmacovigilance signals and information for the adoption of the necessary measures and systematic evaluation of the information. The data will be made available to the pharmacovigilance departments of Medochemie and MEDOCHEMIE LIMITED and may be shared within the company with the other departments concerned. In order to comply with legal obligations, data may be shared with the European Medicines Agency and other national authorities. Medochemie will store your personal data in accordance with effective legislation and its principles for the storage of personal data for the time strictly necessary to fulfill the legal obligation.
Publicly accessible professional information service (PAPIS)
If the controller receives the personal data of the subject in connection with the operation of a publicly accessible information service, the personal data of the subject will be processed for this purpose.
The personal data of the subject are processed to the extent according to the specific request.
Personal data is processed for a period of 10 years.
The legal title of the processing is the fulfillment of a legal obligation.
You have the right to access the data that are being kept by sending an email to dpo@medochemie.com, and request to amend if you do not agree but it is not possible to request deletion of these data.
Information collected for minors under the age of 15
In the event that the individual submitting their personal information to Medochemie is under the age of 15, Medochemie shall require the consent of the parent or legal guardian of the minor.
Contact database for sending news
If Medochemie receives consent from the subject to be included in the contact database, the subject's personal data are processed for the purpose of sending business messages, including the use of electronic means and segmentation to select appropriate messages according to the subject's activity.
For this purpose, the personal data of the subject are processed to the extent according to the granted consent, most often the name, surname, contact details and activity in relation to the Medochemie.
The personal data of the subject are processed for an indefinite period, but at the latest always until the withdrawal of consent.
The legal basis of the processing is consent. Consent is voluntary and can be revoked at any time. The entity has the right to object to the implementation of direct marketing.
Legitimate interest in the protection of the rights of the controller and in defense of proceedings
If Medochemie processes personal data for the reasons stated above, after the completion of such processing, a limited range of data is retained for a longer period of time to provide the necessary documentation for a legitimate interest. The purpose is the need to demonstrate the compliance of the supervisory authority with effective legislation, defense against claims and enforcement of any claims of Medochemie.
For this purpose, the personal data of the subject shall be processed to the extent necessary to demonstrate compliance with the effective legislation of the supervisory authority and / or to the extent necessary to provide evidence in court proceedings.
For this purpose, personal data shall be processed for a maximum period of three years from the end of the previous processing, which is the period during which the supervisory authority may carry out the inspection and this period also corresponds to the limitation period.
The legal title of the processing is the legitimate interest of Medochemie. The subject has the right to object to the processing on the basis of a legitimate interest.
How we store your information
All Sensitive information and personal data that Medochemie obtains, are stored on our local servers/database and all reasonable steps have been taken by Medochemie to ensure that such data is kept secured whilst being stored and/or processed. Information shared within the organisation shall only be accessible to the Senior Management of Medochemie and/or to the personnel with whom such information has been shared.
All hard copy information are maintained in files locally stored by the individual authorised to have access to such information and/or the appropriate manager of Medochemie.
Strict checks and controls are in place to ensure that your personal data shared with us are accessed and shared only with authorised individuals and are processed only for the purposes that such information has been shared.
Further safeguards and processes relating to the collection, maintenance, processing and transfer of your personal data are included in Medochemie’s BCRs.
Website Server
Our website is hosted by Microsoft Inc. Also information shared on our website are shared to a third party company which collates all the information gathered in our website and shares it with Medochemie.
We have taken steps to ensure that all data processors obtaining information shared with Medochemie are fully compliant with the GDPR.
More information about the processing of personal data when browsing this site and the use of cookies here.
How to access your information (and other rights to manage such information)
You have the following rights in relation to personal information we hold about you:
Your right to be informed & to access information
We are transparent in how we collect and process personal information and the purposes that we intent to use it for.
We are obliged, should you request us to do so, to provide you a copy of all your personal information we hold and inform you whether such information is in any matter or form being processed. Should you request it, we can provide you with copies of all the information we have in our possession about you.
Your right to correct information
If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it corrected.
Your right to “be forgotten”
You can ask us to remove your personal information in some circumstances such as that there is no longer a reason for storing your data.
Your right to restrict information
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It will not however, stop us from storing your personal information. We will inform you before we lift any restriction.
Your right to data portability
In certain circumstances you have the rightto obtain personal information you have provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Your right to object
You can ask us to stop processing your personal information, and we will do so, unless we can demonstrate compelling legal grounds for the processing.
The supervisory authority is the Office for Personal Data Protection, to which the subject may file a complaint.
Additional information relating to your rights as the data subject, as well as any necessary forms and documents to be submitted in relation to requests deriving from the above rights, and procedures are available, in the Data Subject Rights Manual of Medochemie.
Dealing with your requests on the basis of exercising the aforementioned rights comes free of charge, provided that your demands are not manifestly unfounded and/or excessive. In the case that your requests are unfounded and/or excessive, Medochemie has the right to apply a reasonable fee for the cost incurred.
Data Controller
The data controller of this website is: Medochemie with above mentioned contact details.
Data Protection Officer
Ms. Giota Andreou
Telephone: 00357 25 852609
Email: dpo@medochemie.com
COOKIES
Browsers like Internet Explorer, Firefox, Google Chrome or equivalents are softwares used to access any webpage and navigate through them.
Cookies are small amounts of text that websites send to your browser to help it navigate through the pages, which often include an anonymous unique identifier. When you visit a website, a computer asks your PC or mobile device for permission to store this file on your computer or mobile device and access information from it. They enable the website owner to distinguish you from other users of the website.
Information gathered through Cookies include the date and time of visits, how you are using the website, whether you have been to the site before and what site referred you to the web page.
Our website uses performance cookies to monitor how the website is used. All information is stored in an anonymous form and no personal data is captured by this site automatically.
We use performance cookies on our website to:
- help improve the website by understanding what pages are popular;
- identify and correct errors;
- provide statistics on how our website is used so we can improve the site; and
- monitor the effectiveness of our marketing.
This means that we may collect information about your computer (including your IP address, operating system and browser type) but no sensitive information about you such as your name, address or date of birth. This is statistical data, used to analyse user’s browsing patterns to help us understand how visitors use the site, and does not identify any individual.
Cookies cannot be executed as code or used to deliver viruses and they cannot enable us to access your hard drive. We cannot read any information on your hard drive even if we store cookies there, we have no other way to intervene in it.
If you don’t want to receive cookies while browsing our website, you can modify your browser and/or mobile device settings so that it notifies you when receiving cookies as further set out below.
The data generated through cookies on Medochemie website can be used for various purposes including the following:
Strictly necessary
These cookies are essential in order to enable you to navigate around the website and use its features, such as accessing secure areas of the website. If you decide to either withhold consent or subsequently block cookies, some aspects of the Site may not work properly and you may not be able to access all or part of the Site.
Performance
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often and if they receive error messages. They are used to improve how a website works in future versions.
Functionality
These cookies allow the website to remember choices you make such as user name, language or region you are in and provide a more enhanced personal experience.
We do not permit any third parties to advertise on our website but we cannot control advertisers that are allowed by internet service providers to advertise whilst you are browsing on the internet.
Medochemie is required by law to obtain your consent for all types of cookies that we place other than those that are “strictly necessary”.
How can you manage your Cookies?
You can learn more about how to manage your cookies by visiting the Help function of your browser, the settings of your mobile device or you can visit www.aboutcookies.org which provides detailed information on managing cookies on popular browsers. Medochemie is not related in any way to this website and shall bear no responsibility of its contents or otherwise.
Please note that any amendments done on your browser when it comes to Cookies will not only affect Cookies from www.medochemie.com but also all other websites you visit, unless steps are taken to specify from which websites you wish to block the Cookies from. If you decide to block Cookies, any preferences associated with that website will be lost.
Google Analytics
Google Analytics is a web analytics tool that helps us understand how visitors engage with our website. Google Analytics enables us to view a variety of reports about how visitors interact with our website so we can improve it.
Google Analytics uses first-party cookies to collect information about how visitors use our site. We then use the information to compile reports and to help us improve our site.
Google Analytics collects information anonymously rendering us unable to identify you. It reports website trends without identifying individual visitors. More information on Google Analytics can be found in Google’s Developer Guides.
You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out or being tracked by Google Analytics across all websites you use, visit the Google Analytics Opt-Out page.
We consider Google to be a third party data processor fully complies with European and Local legislations.
Using our site indicates that you accept the use of our cookies. If you disable them we cannot guarantee how our site will perform.
Other websites
Our website may contain links to other websites to the Medochemie Group of Companies. This Privacy and Cookies Policy applies to all websites of the Medochemie Group of Companies to the same extent
If diversion is made to a third party website kindly note that this Privacy and Cookies Policy shall not apply. Other websites will have their own privacy policies.
MISCELLANEOUS
Security
The Security of your personal information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
In the event of a breach we undertake to report it to the appropriate authorities and notify you as soon as possible and/or as further provided in the GDPR.
Changes to our Privacy and Cookies Policy
This Privacy and Cookies Policy is effective as of 1 January 2021 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.
We reserve the right to upgrade or change our Privacy and Cookies Policy at any time and you should check this Privacy and Cookies Policy periodically. Your continued use of the website after we post any modifications to the Privacy and Cookies Policy on this page, shall constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy and Cookies Policy.
The provisions of this Document are not exhaustive and Medochemie shall at all times ensure full compliance with the GDPR. If any provision is or may in the future be conflicting with the provisions of local and European legislations, such provisions shall be disregarded and the legislation shall prevail.
Medochemie
1. 1. 2021