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CONFIDENTIALITY POLICY

We undertake to observe the confidentiality, in accordance with all the laws and regulations applicable to data protection, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

This policy aims to offer information about the personal data that we collect from you or that you provide to us and the way in which it will be processed by us. Please read the following document carefully, in order to understand our point of view and practices regarding your personal data and our handling thereof.

  1. WHO WE ARE

The data controller is A&D PHARMA MARKETING&SALES SERVICES SRL, a Romanian company headquartered in Str. Ciobanului, No. 133, Mogosoaia, County. Ilfov (the “Company”)]. For further information regarding the Company, please http://www.adpharma-ms.com.

  1. WHAT TYPE OF PERSONAL DATA DO WE PROCESS, FOR WHAT PURPOSES AND ON WHAT GROUNDS?

The Company will collect certain information (“personal data”) about identified natural personal or that may lead to identifying natural persons, that are not provided directly by the concerned person (for example, surname, name, postal address, email address, telephone number).

We will process personal data for the following purposes, on the legal grounds indicated for each of them as detailed in this confidentiality policy.

When visiting our website, we use cookies to automatically collect technical information that could identify the user, such as the IP address, the type of internet browser used to navigate on our website, your operating system, the domain name or the host of the domain through which the user navigates on the website.

The main purpose of using cookies is to help you have an improved navigating experience and, also, for publicity purposes, to be able to offer you customized content, adapted to your interests and preferences. Therefore, to the extent that you expressed your consent regarding the use of cookies, we shall use them to offer you a customized and relevant navigating experience on our website and to understand how you interact with our publicity content.

For further information on the use of cookies on this website and the purposes for their use, as well as the possibility to control and/or deactivate the cookies, please see our Cookie policy. [Please insert the active link to the webpage where the Cookie policy is displayed.]

We will process your personal data, such as surname, name, email address, telephone number and any other information or details that you will provide through correspondence, in order to settle and answer your questions, claims or requests, depending on the communication channel through which you are contacting us, according to the description below.

Purpose Legal ground Duration
1 Providing answers to your questions, claims or requests through electronic correspondence (e-mail) or telephone Processing is based on a legitimate interest, allowing us to provide answers to your questions, claims or requests. 4 years after settling requests

If you choose to apply for a job through the website, as a candidate, the Company processes your personal data in order to perform specific recruiting activities for certain vacant positions within the Company.

The processing of your data for this purpose is based on the endeavors on your application to conclude an employment contract. Providing your data for such purpose is voluntary. Your refusal to provide the data may lead to the Company’s impossibility to consider you during the recruiting process for various positions.

Purpose Processed data categories Legal ground Duration
1 Recruiting The data included in the CV, as well as the other documents sent by the candidate, such as: surname, name, address, email address, telephone number, professional experience, educational background, qualifications, etc. Legitimate interest Throughout the development of the recruitment process
2 Storing your CV after the completion of the recruiting process The data included in the CV, as well as the other documents sent by the candidate, such as: surname, name, address, email address, telephone number, professional experience, educational background, qualifications, etc. Consent 2 year after the date when you provided the data
  1. TRANSFER OF PERSONAL DATA ABROAD

In the context of the above operations, your personal data may be transferred abroad, to states in the European Union (“UE”) or the European Economic Area (“EEA”).

We hereby inform you that any transfer made by the Company in an EU or EEA member state shall observe the legal requirements provided in the GDPR.

  1. HOW LONG DO WE STORE YOUR PERSONAL DATA?

We will store your personal data only for the period necessary to achieve the above processing purposes, while observing the applicable legal requirements, as well as the above-mentioned durations. If, after the expiration of the established duration, the Company establishes it has a legitimate interest or a legal obligation to continue processing your personal data for other purposes, you shall be appropriately informed thereof.

We estimate that the processing activities detailed above will require the storing of personal data either for (i) the legally provided period; or (ii) an unlimited period, if applicable laws and regulations allow it. However, in this case, we inform you that any data processing will cease after receiving your request, that certain or all or your data will be eliminated; (iii) or until the relevant purpose applicable to certain data ceases to exist.

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Once the above-indicated processing period expires and the Company no longer has legal or legitimate reasons to process your personal data, the data will be erased in accordance with its procedures, which can involve archiving, anonymization or destruction.

  1. PROCESSING THE DATA OF CHILDREN UNDER 16

All personal data processing activities presented in this Policy refer exclusively to persons over 16. The use of the processing systems, as well as their results, is forbidden in relation to children below this age without the consent of their parents/legal representatives. If, despite our reasonable efforts to prevent it, such processing is performed, we will cease it upon observing that the users are not of the above-specified age.

  1. DATA PROCESSING SECURITY

The Company hereby informs you that it constantly evaluates and updates the implemented security measures in order to provide a safe and secure processing of personal data.

  1. RIGHTS OF CONCERNED PERSONS

In relation to the processing of your personal data, you have the following rights:

  1. Right to access the processed personal data: you have the right to obtain a confirmation of the fact that your personal data is processed or not and, if so, to gain access to the type of personal data and their processing conditions, by addressing a request to the data controller;
  2. Right to request the rectification or deletion of personal data: you have the possibility of requesting, by addressing a request to the data controller, the rectification of inaccurate personal data, the completion of incomplete data or the deletion of your personal data if (i) the data is no longer necessary for the initial purpose (and there is no new legal purpose), (ii) the legal ground for processing is the consent of the concerned person, the concerned person withdraws their consent and there is no legal ground, (iii) the concerned person exerts the right to oppose and the controller has no prevailing legitimate reasons to continue processing the data, (iv) the data was processed illegally, (v) the request is necessary to comply with the EU or Romanian legislation or (vi) the data was collected in relation to services of the IT company offered to children (if applicable), when specific consent requirements apply;
  3. Right to request a restriction of the processing: you have the right to obtain a restriction of the processing if: (i) you believe that the processed personal data is inaccurate, for a period allowing the controller to verify the accuracy of the personal data; (ii) the processing is illegal, however, you do not want us to erase your personal data, but to restrict their use; (iii) if the controller no longer needs your personal data for the above-mentioned purposes, however, you need the data to determine, exert or defend a right in court or (iv) you opposed to the processing, for the period in which we verify if the data collector’s legitimate grounds prevail over the rights of the concerned person;
  4. Right to withdraw your consent for the processing, when the processing is based on consent, without affecting the lawfulness of the processing activities performed up to that moment;
  5. Right to oppose to data processing for reasons related to your particular situation, when processing is based on a legitimate interest, as well as to oppose, at any moment, to data processing for direct marketing purposes, including profiling;
  6. Right to not make the object of a decision based exclusively on automated processing, including profiling, which produces legal effects for the concerned person or can affect them similarly in a significant manner;
  7. Right to data portability, meaning the right to receive your personal data that you provided to the data controller in a structured, easily accessible and machine-readable format, as well as the right to transfer said data to another controller, in which case the processing is based on your consent or the execution of an agreement and it is performed through automated means;
  8. Right to submit a complaint at the Data Protection Authority (ANSPDCP) and right to address the competent courts.

The rights above may be exerted at any moment. In order to exert such rights, we encourage you to address a written request, dated and signed, or in electronic format at the following address Str. Ciobanului, No. 133, Mogosoaia, County. Ilfov or by e-mail to protectiedate@adpharma.com..

  1. MODIFICATIONS TO THIS POLICY

This Confidentiality policy may suffer modifications from time to time and may be updated by the Company, as necessary. The Company shall notify you about any material or substantial modifications of this Confidentiality policy and shall ensure that said notification is sent in such way that guarantees its acknowledgement by you, for example, by using the provided e-mail address or any other appropriate means for an effective communication.

  1. CONTACT

You can address any question about this document to Data Protection Officer, which can be contacted using the following contact details: protectiedate@adpharma.com.