Privacy Policy
Version: July 2022
The following information will provide you with an easy to navigate overview of what will happen with your Personal Data when you visit www.Promedon-upf.com (the “Website”).
This document is structured as follows: firstly, some key definitions and basic information will be provided, then general privacy information relating to the Website " will be shared and lastly particular cases will be dealt with (for example, specific conditions regarding the processing of data provided through forms).
1. Key Definitions and basic information.
Below are some basic facts. Note however that further detail can be found under the subsequent sections too.
a. What is Personal Data?
The term “Personal Data” comprises all data that can be used to personally identify you.
b. What Personal Data is processed as a consequence of accessing this web site?
The Personal Data that this Website may collect is your IP address and certain Website use analytics (to understand more about this, please see our Cookies Policy ), and eventually, your name, surname, profession, e-mail address, country of residence should you contact us via any of the forms present in the Website. Note that further Personal Data could be voluntarily provided in these forms, thus it is our understanding that you are voluntarily consenting to the processing of any additional category of Personal Data, which will be subject to this Privacy Policy.
c. Who is the responsible party for the recording of data on this website (i.e., the “controller”)?
Personal Data processed by or because of accessing or using certain functionalities of this Website is processed by Promedon GmbH, whose contact information is available below. The “controller” is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of Personal Data.
d. What rights do you have as far as your Personal Data is concerned?
e. How do I exercise the rights that the law grants to EU data subjects?
Please send an email to dataprotection@Promedon.com with your request. Our Data Protection Officer will assess your request and contact you back as soon as possible.
f. Will my Personal Data be shared with third parties?
Promedon GmbH may share the Personal Data collected through this Website with its parent and sister companies. Promedon GmbH will share the Personal Data collected with Promedon S.A., a sister company located in Argentina. Note that Argentina currently holds an Adequacy Decision emitted by the European Commission regarding the adequacy of this territory in regard to European standards of Personal Data processing. This decision can be accessed by clicking here.
Promedon GmbH has taken and shall continue to take the necessary appropriate technical and organizational safeguards in an effort to keep your Personal Data safe
.Promedon GmbH will not share your Personal Data with any other third party, except for webhosting and infrastructure related activities. In that regard, we host our website with All-Inkl. The Provider is the ALL-INKL.COM – Neue Medien Münnich, owner: René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany.
2. General Conditions
The information found below is in addition to that provided above.
a. Grounds for processing
By accessing the Website, you hereby consent to the processing of your Personal Data in accordance with this Privacy Policy.. You can revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.
b. Controller information
As mentioned above, the Data Controller is:
PROMEDON GmbH
An der Alten Spinnerei 5
83059 Kolbermoor - DE
Phone: +49 8031 900400
E-mail: germany@Promedon.com
The Controller’s Data Protection Officer may be contacted by sending an e-mail to: dataprotection@Promedon.com
c. How do we collect your Personal Data
There are two ways we do it:
- You voluntarily provide the Personal Data: Promedon GmbH may require your data to carry out a particular activity (require the sending of information, training, etc.). In this case, you will be warned of the need to provide it, as well as the mandatory or optional nature of its provision. If you contact us by e-mail by sending an email to dataprotection@promedon.com or other address indicated in the Website, all resulting personal data (name, e-mail, request, etc.) will be stored and processed by us for the purpose of processing your request.
- IT systems collect it automatically: The applications provided by Promedon GmbH, whether owned by you or by third parties, may collect certain data while you browse the site, collected without the need for you to provide it. This data shall be recorded by our IT systems automatically or after you consent to its recording during your Website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this Website.
d. How is your Personal Data used?
When your data is collected, the reason for the use is detailed and if it is mandatory, the legitimate basis of processing will be indicated (for example, your consent may be requested). Except for a higher legal authorization, your Personal Data is kept for the purpose for which it was collected, and in accordance with this Privacy Policy.
In the case of IP addresses, their use is related to the appropriate management of the Website. Note that some products seen on the Website may not be available in your country. Therefore, the Website may automatically geo-block the access to certain sections of it. More information on this can be found below under the section “Geo-blocking and automatic redirection” below.
Analytics collected by the Cookies used in the Website serve the purposes described in their Policy, which can be accessed by clicking here.
Personal Data provided through the forms found in the Website will be used to assess your request and provide you with a response.
e. Data Retention Period
Unless a more specific storage period has been specified in this Privacy Policy, your Personal Data will be retained by Promedon GmbH until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your Personal Data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.
f. Transfer to Third Parties.
As mentioned above, Promedon GmbH may share the Personal Data collected through this Website with its parent and sister companies. In particular, Promedon GmbH will share the Personal Data collected with Promedon S.A., a sister company located in Argentina. Note that Argentina currently holds an Adequacy Decision emitted by the European Commission regarding the adequacy of this territory in regard to European standards of Personal Data processing. This decision can be accessed by clicking here.
Promedon GmbH has taken and shall continue to take the necessary appropriate technical and organizational safeguards in an effort to keep your Personal Data safe.
Promedon GmbH will not share your Personal Data with any other third party, except for webhosting and infrastructure related activities
Promedon GmbH, as Data Controller, is responsible for the management of the personal information used by third parties and affiliated companies. You can consult the list of entities by sending an email to dataprotection@Promedon.com.
g. Sensitive Personal Data
We do not collect sensitive Personal Data and you must refrain from providing them to us. Any sensitive Personal Data accidentally collected or unsolicitedly received will be immediately deleted in accordance with applicable Promedon GmbH policies.
Also, note that the Website is not directed to or intended for patients. Please review the Website’s Terms of Use if you have any doubts in connection with the foregoing by clicking here.
h. Geo-blocking and automatic redirection.
The Website may restrain certain Users from accessing parts of it, or automatically re-direct to country specific sections of it.
This is a measure taken by PROMEDON to ensure the intended purpose of the Website is fulfilled, that is, that relevant Users (given the current regulatory and factual circumstances related to the products and services in PROMEDON’s portfolio) to which PROMEDON may be able to provide products, services, and support, are reached. PROMEDON does not intend and does not incur in any unjustified discrimination of Users based on their nationality, place of residence or establishment.
Notwithstanding the foregoing, please be aware that the Regulation on Geo-blocking (EU) 2018/302 is not applicable to the Website given its nature and purpose; the Website does not offer any specific product or service. The products or services depicted on the Website refer to healthcare services, which is excluded from the abovementioned regulation. Furthermore, the Website is not an online shopping platform and does not bear any function which could be associated to one.
Therefore, as mentioned, access to certain parts of the Website may be restricted, or the following text may appear at the top of the Website section the User has accessed which is not supported in the territory related to the User’s IP-address: “Important note: Unfortunately, our products are not available in your country. If you have any questions, please contact our support.”
By the same token, when browsing, automatic redirection may happen to parts of the Website specifically designed to the IP-address related territory of the User.
i. Minors
The content of the Website is aimed to users over 16 years of age. If we become aware that a user under the age of 16 has offered personal information in connection with the Website, we will be immediately deleted in accordance with applicable Promedon GmbH policies. Please review the Website’s Terms of Use if you have any doubts in connection with the foregoing by clicking here.
j. Technical and Organizational Safeguards
All Personal Data received by Promedon GmbH will be treated with the utmost reserve and confidentiality. Our company has established appropriate technical and organizational means to prevent the loss, misuse, alteration, unauthorized access or copying of the Personal Data provided. Notwithstanding the foregoing, it is impossible to guarantee a total security status of the transactions, which is why it enables a query line so that in case of suspecting any unsafe activity, report it to dataprotection@Promedon.com.
k. Your rights
You have the right to receive information about the source, recipients, and purposes of your archived Personal Data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or deleted if there are legal grounds for this. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Note that if you are an EU resident, you are entitled to lodge a complaint with your local Data Protection Authority.
Should you want to exercise any of the abovementioned rights, please send an email to dataprotection@Promedon.com with your request. Our Data Protection Officer will assess your request and contact you back. Please note that additional information may be requested to identify you at the time you make your request. We will comply with your request if appropriate, within the legal term from receipt of your request.
l. Policy updates
This policy is updated periodically, so you should check the date of the latest version, which will determine your compliance with it when browsing. We reserve the right to modify it without notice.
3. Particular Conditions regarding the Contact Forms
By sending your Personal Data through the contact forms found on the Website, you give your consent and authorize Promedon GmbH to collect and process your data that is exposed in each form under this Policy.
You agree to provide true and adequate data, as well as to update them if necessary. The Personal Data that will initially be requested is the following:
- Name and surname
- Type of sender (healthcare professional, healthcare Organization, Payer, Distributor, others).
- Medical specialty about which you are making the query
- Place of residence
- Telephone
- Type of address query
Note that further Personal Data could be voluntarily provided in these forms, thus it is our understanding that you are voluntarily consenting to the processing of any additional category of Personal Data, which will be subject to this Privacy Policy.
We hereby inform you that the provision of Personal Data requested through the forms found on the Website may become part of a Personal Data base created and under the responsibility of Promedon GmbH in order to collect data to, mainly, classify queries according to type of public and refer to the corresponding customer service manager.
Likewise, these same data may be used to:
- Address requests: send information, contact you, notify you of any changes to terms, conditions, and policies and/or other administrative information; and
- Legitimate Business purposes: data analysis, auditing, improving the site, improving products and services and identifying Site usage trends.
The data obtained through forms found on the Website may be combined with other data held by Promedon GmbH and its affiliates, or subsequently obtained by any of them.