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Personal Data Policy

1. Scope of the Personal Data Policy

1.1 The following describes how Nordic Drugs AB, org. reg. no. 556505-5141, with the address Box 300 35, 200 61, Limhamn, ("Nordic Drugs", "us" or "we"), processes personal data in relation to you. 

1.2 Protection of privacy is a priority for us. It is therefore important for us to protect your personal data and ensure that we process it in a correct and lawful manner. 

1.3 In this privacy policy, we explain the types of personal data we may process and the purpose for which we process it. We also give an account of our processing of personal data and your choices and rights in relation to it. Please read our privacy policy carefully to familiarise yourself with its contents. The personal data policy is available on our website, https://www.nordicdrugs.se/. 

1.4 Please note that this personal data policy concerns the processing of personal data for which Nordic Drugs is the personal data controller. That means that we are responsible for handling and processing your personal data. It also means that you should contact us if you have any questions or comments or if you wish to exercise any of your rights in relation to our processing of your personal data. 

1.5 We may collect personal information on you from various different sources, including directly from you personally or from your employer. We may also collect other personal information on you from public sources such as databases and websites.


2. Personal data that is processed

Contact persons and private individuals 
2.1 Personal data refers to information that can be related to you. We may process the following personal data that may be related to you as (i) a contact person at one of our corporate customers, a carer or other partner with which we collabo-rate (referred to collectively as "Corporate Customers") or as (ii) a private individual: 
(a) name; 
(b) e-mail address;
(c) telephone number; 
(d) details of your employer and title (not applicable to private individuals); and
(e) any personal data contained in communication between you and Nordic Drugs (e.g. in an e-mail message or a form completed on the website).


Practitioners of clinical drug studies 
2.2 We may process the following personal data on you as a practitioner of clinical drug studies: 
(a) name; 
(b) telephone number; 
(c) e-mail address; and 
(d) address. 

Recipients of pharmaceutical samples 
2.3 We may process the following personal data on you as a recipient of pharmaceutical samples: 
(a) name; 
(b) address; 
(c) e-mail address; and
(d) telephone number.

Visitors to the website 
2.4 We may process the following personal data that can be related to you as a visitor to our websites: 
(a) IP address; and 
(b) tracking cookies. 


Job applicants 
2.5 In addition, we may process the following personal data that can be related to you as a job applicant at Nordic Drugs:
(a) name; 
(b) personal identity number; 
(c) address; 
(d) e-mail address; 
(e) telephone number; 
(f) CV and personal statement.


3. The purpose of the processing and legal basis

Contact persons and private individuals 
3.1 When, as a contact person or as a private individual, you submit a question about a drug or an enquiry regarding remittance of material to Nordic Drugs via an e-mail message or via the form on our website, Nordic Drugs processes your personal data (2.1) in order to answer your question or enquiry. If you are a contact person at a Corporate Customer, Nordic Drugs processes your personal data for this purpose on the basis of Nordic Drugs' legitimate interest in answering ques-tions and enquiries from its Corporate Customers efficiently. If you are a private individual, a question on a drug may constitute sensitive personal data. In that case, your personal data is processed on the basis of your consent. 

3.2 When, as a contact person or private individual, you submit a complaint about a drug via an e-mail message or a form on our website, your personal data (2.1) is processed for the purpose of managing such complaints. If you are a contact person at a Corporate Customer, Nordic Drugs processes your personal data for this purpose on the basis of the fact that such is necessary for Nordic Drugs in order to comply with Nordic Drugs’ legal obligations relating to complaints about drugs. If you are a private individual, a complaint about a drug may constitute sensitive personal data. In that case, your personal data is processed for this purpose on the basis of the fact that it is necessary for reasons of public interest, such as ensuring high standards of quality and safety for drugs. 

3.3 When, as a contact person or as a private individual, you notify Nordic Drugs of an adverse reaction to a drug, Nordic Drugs processes your personal data (2.1) in order to report such adverse reactions to the Swedish Medical Products Agency or to the European Medicines Agency (EMA) as well as to comply with the documentation requirement in the European Medicines Agency’s Guidelines on Good Pharmacovigilance Practices (GVP). If you are a contact person at a Corporate Customer, Nordic Drugs processes your personal data for this purpose on the basis of the fact that such is necessary in order to comply with Nordic Drugs’ legal obligations relating to the reporting of adverse reactions. If you are a private individual, data on an adverse reaction may constitute sensitive personal data. In that case, your personal data is processed for this purpose on the basis of the fact that it is necessary for reasons of public interest, such as ensuring high standards of quality and safety for drugs.

3.4 If you are a contact person at a Corporate Customer, your personal data (2.1) is also processed to manage the business relationship with the Corporate Customer at which you are our contact person. Your personal data is processed for this purpose on the basis of Nordic Drugs' legitimate interest in managing its business relations efficiently. 

Practitioners of clinical drug studies 
3.5 If you are a practitioner of clinical drug studies, Nordic Drugs processes your personal data (2.2) in order to document which drug studies we have provided drugs for and to manage contact with the persons responsible for those studies. If you are a contact person at a company or other organisation that conducts drug studies, Nordic Drugs’ processing of your personal data is based on Nordic Drugs’ legitimate interest in managing contact with the persons responsible for drug studies for which Nordic Drugs provides drugs. If you personally are a tester or a sponsor in clinical drug studies, Nordic Drugs’ processing of your personal data is based for this purpose on the fact that Nordic Drugs needs to comply with Nordic Drugs’ legal obligations regarding documentation requirements for clinical drug studies. 

Recipients of pharmaceutical samples 
3.6 If you are a recipient of pharmaceutical samples for purposes other than clinical drug trials, Nordic Drugs processes your personal data (2.3) for the purpose of registering recipients of pharmaceutical samples. Processing of your personal data for this purpose is based on the fact that it is necessary for Nordic Drugs to comply with Nordic Drugs’ legal obligations regarding registration of recipients of pharmaceutical samples. 

Visitors to the website 
3.7 If you are a visitor to Nordic Drugs’ website https://www.nordicdrugs.se/, its Finnish, Norwegian, Danish and international counterparts and the product websites we operate (such as proibs.se, gaviscon.se, gaviscon.nu, gavisconnordic.fi, gavisconnordic.no, hidrasec.dk, hidrasec.fi, hidrasec.se, comfora.se, dimor.se, nasoferm.se), Nordic Drugs processes data on your IP address and tracking cookies for the purpose of analysing user behaviour and compiling statistics. The data is processed on the basis of Nordic Drugs’ legitimate interest in improving our website. 

Job applicants 
3.8 If you are a job applicant at Nordic Drugs, Nordic Drugs processes your personal data (2.5) for the purposes of managing the recruitment process and conducting recruitment tests and evaluating your suitability for employment with us. The processing takes place on the basis of Nordic Drugs’ legitimate interest in recruiting and being able to evaluate the applications we receive. If you give your consent for Nordic Drugs’ processing of your personal data for future recruitments, that future processing will be based on your consent.

 

4. Storage of personal data

4.1 We store your personal data for as long as is necessary to fulfil the purpose of the processing in accordance with the thinning times specified below. 

Contact persons and private individuals 
4.2 Personal data on contact persons or private individuals that is processed for the purpose of responding to questions and enquiries is stored until the case to which the question or enquiry relates has been closed. 

4.3 Personal data on contact persons or private individuals that is processed for the purpose of dealing with complaints is retained for five years after the complaint was made. 

4.4 Personal data on contact persons or individuals that is processed for the purpose of reporting adverse reactions is stored for ten years after Nordic Drugs' authorisation to sell the drug to which the adverse reaction relates has ceased to apply. This is in accordance with the European Medicines Agency Guidelines on Good Pharmacovigilance Practices (GVP). 

4.5 Personal data on contact persons that is processed for the purpose of managing the relationship with the Corporate Customer at which the contact person is employed is stored for six months from the end of the relationship with the Corporate Customer. Contact persons' personal data can also be stored for the period for which it is necessary for Nordic Drugs to process the data in order to carry out its day-to-day operations. 

Practitioners of clinical drug studies 
4.6 Personal data on contact persons at a practitioner of clinical drug studies that is a company or organisation is stored by Nordic Drugs for two years from the end of the drug study. If the practitioner is a private individual such as an individual doctor, Nordic Drugs stores the personal data for five years in accordance with the Swedish Medical Products Agency's regulations. 

Recipients of pharmaceutical samples 
4.7 Personal data relating to pharmacy managers and persons authorised to prescribe drugs who receive pharmaceutical samples is stored for five years in accordance with the European Commission guidelines on good distribution practice. 

Job applicants 
4.8 Personal data on job applicants is stored for the duration of the recruitment process in question. If you have given your consent for Nordic Drugs to also store your personal data for future recruitments, your personal data is stored for two years or until you withdraw your consent. 

4.9 If your personal data is no longer necessary to fulfil the purpose of the processing or if the processing is no longer permitted for any other reason, the data will be anonymised or erased. However, we will always store your data for as long as is required by law.

 

5. Cookies

When you visit our websites, data about your use of the website may be collected by such means as Google Analytics. This tracking technology uses cookies to collect aggregated data on website usage and activity, such as how many users visit the website and how often. This data may be shared with a third party for the purpose of further improving our websites. We use cookies for that purpose and on the basis of our legitimate interest in better understanding your use of our websites and improving the user experience on the websites. For more information about the cookies we use and for how long they are stored, see our cookie policy, which is available on our website.

 

6. Recipients

6.1 We may share your personal data with the following categories of recipients: 
(a) other companies within the group;
(b) an authority, court or other third party where we consider disclosure to be necessary (i) under an applicable law or regulation, (ii) to file, establish or defend a legal claim, or (iii) to protect your or another person's fundamental interests;
(c) a potential purchaser (and its representatives and advisors) in connection with a proposed purchase, merger or acquisition of any part of our business, provided that we inform the purchaser that it may only process your personal data in accordance with this personal data policy; and
(d) another party with your consent to share your personal data. 

6.2 Personal data is shared within the group for the purpose of streamlining and centralising Nordic Drugs’ operations. The processing takes place on the basis of our legitimate interest in being able to streamline administration and management within the group and to streamline operations. 

6.3 We may also disclose your personal data to our personal data processors, e.g. companies engaged in invoice administration or IT and cloud services. In such cases, personal data processing agreements are entered into to ensure that your personal data is processed in accordance with this privacy policy.

 

7. Transfer of personal data to a third country


If data is transferred or processed outside the EU/EEA, it will only be processed when such transfer or processing is permitted in accordance with Articles 45-49 of the Data Protection Ordinance. To obtain a copy of the security measures that have been adopted or to obtain information on how to access them, please contact privacy@nordicdrugs.se.

 

8. Your rights

8.1 You have the right to obtain confirmation of whether we process personal data relating to you and, if so, to access that personal data and also information about the personal data and our processing of it. 

8.2 You have the right to have inaccurate personal data relating to you corrected by us without undue delay. You also have the right in certain cases, depending on the purpose of the processing, to supplement incomplete personal data. 

8.3 You have the right under certain circumstances to have your personal data erased by us, e.g. if the personal data is no longer necessary to fulfil the purposes for which it was collected or if the personal data has been unlawfully processed. 

8.4 You have the right to require us to restrict the processing of your personal data in certain cases. For example, if you contest the accuracy of the personal data, you may require us to restrict the processing of it for the time it takes us to verify the accuracy of the data. 

8.5 You have the right to object to processing of your personal data that takes place on the basis of Nordic Drugs' legitimate interest. If that occurs, we must demonstrate compelling legitimate reasons that outweigh your interests, rights and freedoms in order to continue the processing.

8.6 You have the right to object to the processing of your personal data if the processing takes place for direct marketing purposes. In the event of such an objection, we will no longer process your personal data for that purpose. 

8.7 You have the right at all times to revoke your consent to the processing of your personal data. If your consent is thus revoked, Nordic Drugs will terminate any personal data processing based on your consent. 

8.8 You have the right under certain circumstances to obtain the personal information that you provide to us and that relates to you in an electronic format that is widely used. You have the right to transfer such information to another personal data controller (data portability). 

8.9 If you have any comments on how we process your personal data, you are welcome to contact us at the e-mail address listed below. You are also entitled to submit a complaint to the Swedish Data Protection Authority. 

 

9. Additions and changes

We may make additions or changes to this personal data policy. If we make any such additions or changes, we will post the updated policy on our website. If that occurs, please read the updated personal data policy carefully. 

 

10. Contact us

In order to update, correct or erase data we have on you or to exercise your rights in accordance with the above, you are welcome to contact our data protection officer at privacy@nordicdrugs.se.

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This personal data policy applies from 3 December 2018.

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