Laboratoire HRA Pharma (hereafter “HRA Pharma”), ID number 420 792 582 RCS Nanterre located 200 avenue de Paris, F-92 320 Châtillon, France, and its subsidiaries pay particular attention to the protection of your Personal Data and to privacy and commits to respect them through the following fundamental values:
- to respect individuals expectations regarding the use of their Personal Data,
- to build and preserve trust of our consumers and other involved people or organizations,
- to prevent any damage with Personal Data and privacy,
- and to be compliant with the letter and the spirit of Laws and Regulations regarding Personal Data protection.
HRA Pharma provides on-line resources with the aim to give health information such as contraception.
The following terms “Personal Data”, “Processing”, “Controller”, “Processor”, “Data Protection Authority” take the definitions given by article 4 of the GDPR.
- Information collected about you when you access this website
- Personal Data which are directly shared by you when you contact us: both your name and your email address.
- Information collected about you through the use of the Website without being actively provided by you, thanks to several technologies, notably internet protocol (IP) addresses, cookies, Internet tags, browsing data. Main categories of data which are collected are:
- Domain and server (host) from which you access this website on the Internet;
- Address of the website from which you access our website
- Date, time, length of visits of this website and pages most frequently accessed;
- Your internet protocol (IP) address;
- Operating system of your computer and details of your web browser.
- Data Protection with the Chatbot Ella
The Chatbot Ella is providing you with personalized automated information about contraception and emergency contraception.
HRA Pharma UK & Ireland Ltd fully respects confidentiality of your data in compliance with European General Data Protection Regulation No. 2016/679 (GDPR) and would like to be transparent on how your personal data is used while chatting.
To engage with you in the chat, we use your Facebook–Page scoped ID (PSID), this means we use Facebook first name, your Facebook surname, the time zone offset to CET (Central European Time) such as CET – 5, the language setting such as en_us for English in the US and your gender specified in Facebook.
Other parties are also processing data on HRA Pharma’s behalf are bound by confidentiality:
For technical support: Spectrm Publishing UG, Bredower Str. 31, 14612 Falkensee, Germany
For medical support: Cambridge Regulatory Services Ltd, 2 Cabot House, Compass Point Business Park, St. Ives, Cambridgeshire, PE27 5JL, United Kingdom.
For commercial support: Dirt & Glory Media, 2 Hat & Mitre Court, London, EC1M 4EF, United Kingdom
At any time, by sending the Stop message, your data will be deleted immediately.
Data regarding side effects are stored according to pharmaceutical regulation (while the product is sold and ten years thereafter).
- What are the purposes for processing and the legal basis?
|Managing and responding to your questions||Comply with our legal obligations and with our legitimate interest to answer your questions|
|Managing information received concerning adverse effects or quality claim||Comply with our legal obligations|
|For our commercial needs, notably data analysis, our website improvement, both our products and services improvement, identifying use of the website trends, customization of the website according to your tastes and to determine the efficacy of our promotional campaigns||Comply with our legitimate interest to develop our relation with you|
- Who are the recipients of your Personal Data?
The access to your Personal Data is strictly limited to authorized people at HRA Pharma. These people are the ones for whom the access to such data is necessary to carry out their missions.
In addition to the categories of recipients above mentioned, the company LOOP, our IT solution provider and hosting company, located in Austria in Europe, may have access to your Personal Data.
HRA Pharma will also communicate your Personal Data to relevant authorities as required by applicable laws.
In every case, your personal data will be processed according to applicable laws regarding protection of Personal Data and particularly according to the GDPR.
- How long will your Personal Data be retained?
Personal Data which are processed to manage and answer to your questions are stored for one year.
Personal Data which are processed to follow an adverse event or a quality claim are stored for ten years starting from the end of the marketing authorization of ellaOne.
Personal Data which are processed for our commercial needs are stored for one year.
- Transfers outside of the European Economic Area
Your Personal Data will not the processed outside of the European Economic Area.
Only aggregated data or anonymized data should be processed out of the European Economic Area.
HRA Pharma implements appropriate technical and organizational measures to ensure an appropriate level of security regarding the risk incurred and protect your Personal Data against unauthorized access, disclosure, alteration or destruction.
- What are your rights? How can you exercise them?
Under applicable Personal Data protection laws, notably the GDPR you have a number of rights with regard to your Personal Data. Those rights are as follows:
- Right to Access – You can ask to see the personal information HRA Pharma holds about you. In connection with a request, HRA Pharma may request specific information about you to enable us to confirm your identity and right access, as well as search for and provide you with the personal information HRA Pharma holds about you. In the event we cannot provide you with access to your personal information (for instance, personal information may have been destroyed, erased or made anonymous), we will inform you of the reasons why.
- Correction or Deletion of Personal Information – HRA Pharma works to ensure that personal information in its possession is accurate, current and complete. If you believe that the personal information HRA Pharma holds on you is incorrect, inaccurate, incomplete or outdated, you may request the revision or correction of that information. If it is determined that personal information is inaccurate, incomplete or outdated, we will revise it.
- Withdrawal of Consent – If you have provided consent for the processing of your data, you have the right to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.
- Objection to processing – you have the possibility to object to the processing of your personal data including profiling, on grounds relating to your particular situation as provided by Data Protection law. When profiling is related to direct marketing you always have a right to object.
- Limitation to processing – you have the right to obtain from us restriction of processing in certain instances as provided by data protection law.
- Right to data portability – you have the right to receive the personal data, which you have provided to us, in a structured, commonly used and machine-readable format when the processing is based on your consent or on a contract. You also have the right to ask us to transmit it to another data controller of your choice.
- Complaints – You have the right to lodge a complaint to the Data Protection Authority, if you believe that HRA Pharma has not complied with the requirements of the GDPR with regard to your personal data.
If you wish to exercise one of these rights, please send a request in this regard to firstname.lastname@example.org or to Laboratoire HRA Pharma, Data Protection Officer, 200 avenue de Paris, 92320 Châtillon, France, stating both your name and your surname, with a copy of your identity card.
If you have unresolved concerns you also have the right to complain to the Data Protection Authority in the country where either you live or either you work or either the country of the place of the alleged infringement.
Effective date: April 2019