Who We Are

Pharegistrum – Pharmaceutical and Technical Consultancy, Ltd., headquartered at LEAP Areeiro, Hundred Lisboa Business Center | GC 30, Av. Almirante Gago Coutinho, nº 30, 1st floor, 1000-017 Lisbon, in Lisbon, with NIPC and registration number 508288410 (“Pharegistrum”), understands the importance of handling the personal data of users of this website (the “Site”) in accordance with applicable laws on personal data protection, to ensure respect for the privacy online of these users. Thus, Pharegistrum has prepared this Privacy Policy to explain to Site users how their personal data may be used when they use the Site.

Below, you can find detailed information about the different processing activities that Pharegistrum may carry out using personal data provided by Site users, or otherwise collected through the Site by Pharegistrum. In any case, any processing of personal data done by Pharegistrum will follow the following principles:

• Pharegistrum will only process personal data when legally permitted by the General Data Protection Regulation (“GDPR”) and/or other local laws that may apply in each case (e.g., the GDPR Implementation Act). All personal data processing carried out by Pharegistrum will take into account the rights and freedoms of the data subjects involved;
• Pharegistrum will strive to inform individuals about how their personal data may be processed;
• Pharegistrum will only process personal data for specific purposes (described below), and will retain such personal data only for the period necessary to achieve those purposes;

Pharegistrum will not collect more personal data than needed to achieve the mentioned purposes, and will strive to ensure that such personal data remains accurate, up-to-date, and confidential.

Who is Responsible for the Personal Data Processed through the Site?

Pharegistrum, identified at the beginning of this Privacy Policy, is responsible for the processing of all personal data obtained through the Site. Pharegistrum can be contacted in writing via the following email address: info@pharegistrum.com.

What Types of Personal Data Can Pharegistrum Collect about Me?

When you use the Site, or certain areas of the Site, Pharegistrum may be able to collect information about you as an individual. This information may directly identify you or be associated with you through other information held by Pharegistrum (or by third parties). In this case, this information is legally qualified as “Personal Data”.

Below is a list of categories of Personal Data that Pharegistrum may collect through the Site:

Contact form

The Site contains contact forms, which can be used to send any messages, such as contacts, requests, suggestions, or complaints. To submit a contact request through these forms, you will need to provide Pharegistrum with some Personal Data about yourself:

• Name;
• Contact email.

Personal Data relating to other people

The Site contains certain areas with free text fields (such as the contact forms mentioned above), which users may use to (inadvertently or not) disclose Personal Data relating to other people. Additionally, users who contact Pharegistrum may (inadvertently or not) include Personal Data relating to other people in the messages they exchange with Pharegistrum.

In any situation where you decide to share Personal Data relating to other people, you may be considered responsible for the processing of those data, independently of Pharegistrum. This means you may be held accountable for that decision, including for any damages caused to the third parties whose Personal Data have been shared.

Therefore, in such situations, it is important to ensure that you can lawfully share such Personal Data with Pharegistrum, under applicable law – for example, having obtained the consent of the third parties involved, verifying a legal obligation to share the Personal Data, or having a legitimate interest in sharing those data, etc.

Browsing data

The operation of the Site – as is the norm with any Internet sites – involves the use of computer systems and processes of software that collect information about Site users through their normal operation. Although Pharegistrum does not use this information to associate it with specific users, it may be possible to identify those users using such information, either directly or in combination with other collected data – as such, this information is also considered Personal Data.

This information includes various parameters related to your operating system and device used to access the Site, including your IP address, your location (country), the domain names of your device, the URI addresses (Uniform Resource Identifier) of the resources you access on the Site, the dates/times you access such resources, the method used to request access to such resources, the sizes of files you may download in response to such requests, the numeric code associated with the status of the response sent by the server (complete, error, etc.), among others.

Cookies

Settings, features, and standards applied

The cookies are small text files that can be sent to your device and stored by the Internet sites you visit, and later sent back to those sites when you revisit them. It is thanks to these  cookies that those Internet sites can “remember” your options and preferences (e.g., login data, chosen language, font size, etc.), so you don’t have to reconfigure or re-enter them when you revisit a given Internet site or when you change pages within an Internet site. login, chosen language, font size, etc.), so you don’t have to reconfigure or re-enter them when you revisit a given website, or when you navigate to a different page within a website.

The cookies can also be used as a form of electronic authentication, session monitoring, and storing information related to your activities when accessing an Internet site. They may also contain a unique identification code that allows tracking your navigation on an Internet site for statistical purposes or to direct advertising to you. Some functions on certain Internet sites may not work correctly without the use of  cookies which, in certain cases, may be necessary for the use of those Internet sites.

When browsing an Internet site, you may also receive cookies from other Internet sites or other servers (“third-party cookies”).

There are various types of cookies, varying according to their characteristics, functions, and storage periods on your device: “browsing/session cookies,” which are typically automatically deleted when you close your browser, and “persistent cookies,” which remain stored on your device until their expiration date is completed.

Under applicable law, your consent is not always required for the use of cookies on an Internet site. Specifically, “technical/functional cookies –” that is,  cookies that are used solely to carry out or facilitate the transmission of communications through an electronic communications network, or that are necessary to provide a service you have requested – typically do not require your consent. This may apply to  browsing/session cookies (e.g., when used to allow users to access their accounts) and technical/functional cookies (e.g., when used to remember choices made by a user within an Internet site, such as the chosen language).

On the other hand, “profiling cookies –” that is, cookies used to create profiles about users to send advertising to those users tailored to the preferences they reveal during Internet browsing – typically require specific user consent.

Cookies used on the Site

The Site uses the following types of cookies:

• Browsing/session cookies, strictly necessary for the operation of the Site;
• Technical/functional cookies, used to enable specific features on the Site and to configure the Site according to your preferences (e.g., regarding the use of cookies, regarding the display of the Site), to enhance your user experience.

Cookie names:

• _cfduid
• PHPSESSID
• cookieconsent_status

Definições de cookies

You can block or delete the cookies used on the Site through the options of your browser. Your preferences regarding  cookies chosen in a browser will not be transmitted if you use a different browser to access the Site. For more information on how to set your preferences regarding  cookies through your browser, see the instructions below.

• Internet Explorer;
• Firefox;
• Google Chrome;
• Safari.

You can also set your preferences regarding third-party cookies through online platforms like AdChoice. 

NOTE: If you decide to block or delete technical/functional cookies used by the Site, it may become impossible to navigate the Site. Certain services or features of the Site may become inoperative or other errors may occur in the operation of the Site. In this case, you may also have to modify or manually enter some information or preferences each time you visit the Site.

Why does Pharegistrum use the Personal Data it collects?

The Personal Data collected by Pharegistrum through the Site may be used for one or more of the following purposes:

• Response to contact requests

Pharegistrum will use the Personal Data you submit with your contact request to ensure that Pharegistrum receives the contact requests you submit through the contact forms provided for this purpose on the Site, as well as to manage those requests and respond to you appropriately and promptly.

In this context, Pharegistrum may also use the Personal Data you submit with your contact request to send you important information regarding the Site’s services (e.g., service updates or terms applicable to the Site, etc.).

• This Personal Data must necessarily be provided for these tasks to be fulfilled by Pharegistrum; if such Personal Data is not provided, it will not be possible to submit a contact request.

Prevention of abuse/fraud

Pharegistrum will use the Personal Data it collects about your activity on the Site, as well as from its other users, to prevent and detect abuse in the use of the Site, or any fraudulent activities carried out through the Site.

Compliance with legal obligations

Pharegistrum will use Personal Data to the extent strictly necessary to comply with any legal or equivalent obligations to which Pharegistrum is subject, which require the collection and/or additional processing of certain types of Personal Data.

• When you disclose Personal Data to Pharegistrum, Pharegistrum is obliged to process your Personal Data under applicable law, which may include retaining and reporting such Personal Data to competent public authorities, so that Pharegistrum can fulfill its legal or equivalent obligations.

Can Pharegistrum use my Personal Data for these purposes?

As mentioned at the beginning of this Privacy Policy, Pharegistrum will only process personal data when legally permitted by the GDPR and/or other local laws that may apply in each case (e.g., the GDPR Implementation Act).

In particular, the legal grounds on which Pharegistrum relies for each of the above purposes are as follows:

• Response to contact requests

The processing and storage of your Personal Data for this purpose is necessary to provide you with services through the Site, and/or following a contract sent through the Site, and as such, is necessary for the performance of a contract to which you are a party, or to respond to a request directly made by you, under Art. 6(1)(b) of the GDPR.

Prevention of abuse/fraud

The processing of your Personal Data for this purpose is necessary for Pharegistrum to prevent and detect abuse of the Site or fraudulent activities carried out through the Site, thereby ensuring the integrity and availability of the Site. These objectives are foreseen as constituting legitimate interests of the data controllers, in Recital 47 (“ The processing of personal data strictly necessary for the purposes of prevention and control of fraud also constitutes a legitimate interest of the controller.”) and 49 (“The processing of personal data, to the extent strictly necessary and proportionate to ensure network and information security … constitutes a legitimate interest of the controller”). Thus, it is reasonable to consider that Pharegistrum has a legitimate interest in processing Personal Data for this purpose, under Art. 6(1)(f) of the GDPR.

Compliance with legal obligations

The processing of your Personal Data for this purpose is necessary for the fulfillment of legal obligations to which Pharegistrum may be subject, under Art. 6(1)(c) of the GDPR.

With whom does Pharegistrum share my Personal Data?

Pharegistrum may share the Personal Data it collects about you through the Site with the following categories of recipients:

• Individuals, companies, or other organizations contracted by Pharegistrum to provide services related to the management and operation of the Site (e.g., Site hosting services, data storage services, email/SMS sending services, maintenance services, billing and accounting services), which generally act as subcontractors on behalf of Pharegistrum;
• Individuals authorized by Pharegistrum to access the Personal Data strictly necessary to carry out activities related to the operation of the Site, who have assumed a confidentiality obligation or are subject to a legal confidentiality obligation regarding the same (e.g., employees, collaborators, and partners of Pharegistrum).
• Entities and public authorities to whom your Personal Data must be disclosed, under applicable law and/or in accordance with binding orders issued by such entities or authorities.

Will my Personal Data be transferred to other countries?

The service provider used by Pharegistrum to host the Site is located in Portugal, so the Personal Data disclosed or collected through the Site will not be transmitted to any country outside the EU. 

How long will Pharegistrum retain my Personal Data?

As mentioned at the beginning of this Privacy Policy, Pharegistrum will retain Personal Data only for the period necessary to achieve the purposes for which it was collected. Specifically, the retention periods that Pharegistrum applies, regarding each of the purposes mentioned above, are as follows:

• Response to contact requests

The Personal Data processed for this purpose will be retained for the period considered strictly necessary to allow the proper management and response to a contact request submitted through the Site.

Generally, if Pharegistrum considers that a particular contact request addressed to Pharegistrum is resolved, Pharegistrum will retain the Personal Data related to that request until one year after the date of the last message sent (by the user or by Pharegistrum). However, this retention period may be extended as necessary for internal audit and security purposes (e.g., when included in  backups that may be made), as well as, in general, to protect Pharegistrum’s interests regarding any claims or legal actions that may arise concerning this processing of Personal Data.

Prevention of abuse/fraud

The Personal Data processed for this purpose will be retained for a general period of six months. If they become necessary for the declaration, exercise, or defense of Pharegistrum’s rights in a legal process, or for potential reporting of detected criminal activity, the  logs needed will be retained as long as necessary to achieve these purposes.

Compliance with legal obligations

The Personal Data processed for this purpose will be retained according to the periods required by the legal obligation in question.

What are my rights? How can I exercise them?

Under the GDPR, whenever your Personal Data is processed by Pharegistrum, you may exercise the following rights:

• Right of access. Under Article 15 of the GDPR, you have the right to receive confirmation as to whether your Personal Data is currently being processed by Pharegistrum or not. You also have the right to access this Personal Data, as well as receive a copy of this Personal Data and additional information about the terms under which such Personal Data is processed by Pharegistrum.
• Right of rectification. Under Article 16 of the GDPR, you have the right to ask Pharegistrum to correct or update your Personal Data if it is incorrect or incomplete.
• Right to data erasure. Under Article 17 of the GDPR, you have the right to request the deletion of your Personal Data processed by Pharegistrum. This right is also known as the “right to be forgotten”. Please note that the conditions for exercising this right are practically limited – essentially, you may exercise this right whenever the processing of your Personal Data is in any way unnecessary or unlawful.
• Right to restriction of processing. Under Article 18 of the GDPR, you have the right to ask Pharegistrum to limit the processing of your Personal Data. This means that Pharegistrum must keep this Personal Data “frozen” (i.e., Pharegistrum can continue to store this Personal Data but cannot alter or use it except for limited purposes) for a certain period. You may exercise this right whenever you believe that your Personal Data processed by Pharegistrum is incorrect, does not need to be processed (or is unlawfully processed), or when you have previously objected to the processing of your Personal Data (as explained below).
• Right to data portability. Under Article 20 of the GDPR, you have the right to receive the Personal Data you have provided to Pharegistrum in a structured, commonly used, and machine-readable format, so that you can transmit this Personal Data to others. Please note that this right does not apply to all your Personal Data that may be processed by Pharegistrum, but only to those collected based on your consent, or the necessity of such collection for the execution of a contract in which you are a party.
• Right to withdraw consent. Under Article 7, paragraph 3 of the GDPR, if you have given Pharegistrum consent to process your Personal Data for a specific purpose, you have the right to withdraw that consent later, free of charge. Please note that any processing of your Personal Data carried out before your withdrawal of consent will not become unlawful as a result of that withdrawal.

You may also have the right to object to the processing of your Personal Data, under Article 21 of the GDPR. This will be the case if there are reasons related to your particular situation that should lead Pharegistrum to stop processing your Personal Data (for example, because it would be unfair to you) – you will need to specify these reasons when you decide to exercise this right. Pharegistrum may contest your objection if it believes there are compelling and legitimate reasons for the processing of your Personal Data to continue.

In any case, you can exercise any of the rights mentioned above in writing, by sending a message to Pharegistrum through the following email address: info@pharegistrum.com.

Finally, as a data subject, if you believe that Pharegistrum has processed your Personal Data unlawfully, or if you do not agree with any response received from Pharegistrum regarding a request you have made concerning your Personal Data, you have the right to file a complaint with the competent supervisory authority – the National Data Protection Commission (CNPD).

Changes to this Privacy Policy

This version of the Privacy Policy became effective on October 18, 2019. Pharegistrum may, from time to time, make changes to the Privacy Policy, including when necessary to comply with applicable law. If any of these changes are substantial, Pharegistrum will inform Site users through a message sent to their email (when they have provided it to Pharegistrum), or through a pop-up available on the Site.

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