GENERAL INFORMATION

Pharmasal Limited, which forms part of the VJ Salomone Ltd group, is committed to respecting your privacy and protecting your personal data. Pharmasal Limited takes the security of your personal data very seriously, and endeavours to be transparent, by providing information on the categories of personal data collected, and the purpose for collecting such personal data.

This Privacy Policy describes how we manage, process and store personal data submitted through the use of our website.

For this purpose, this privacy policy provides you with information on the following:

• Who is the data controller?
• What is Personal Data and what are Special Categories of Personal Data?
• Purpose of website and type of personal data collected
• What is the lawful basis for collecting and processing Personal Data?
• Who do we share your Personal Data with?
• Security, storage and transfer of your Personal Data
• For how long will we retain your data?
• What are your rights as a data subject?
• How to contact us
• Links to websites
• Do we use Cookies?
• How do we use Cookies?
• Cookie removal tips
• Changes to this Privacy and Cookies Policy

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WHO IS THE DATA CONTROLLER?

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In this Privacy Policy (this “Policy”), “Pharmasal”, “we”, “us” or “our” means Pharmasal Limited, (a company incorporated in Malta with principal offices at V.J.Salomone Limited, Upper Cross Road, Marsa, Malta). Our VAT registration number is MT1592-2405 while our company registration number is C27308.

All personal data obtained by us is held and used in compliance with this Policy, with the Maltese Data Protection Act (Cap. 586 of the Laws of Malta), and the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council (hereafter referred to as the “GDPR”). Pharmasal Limited is deemed a “data controller” for the purposes of the GDPR.

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WHAT IS PERSONAL DATA AND WHAT ARE SPECIAL CATEGORIES OF PERSONAL DATA?

Under the GDPR, personal data consists of any information relating to an identified or identifiable natural person ('data subject').

The GDPR provides special categories of data relates to the processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, the processing of genetic data, biometric data for the purpose of identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

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PURPOSE OF WEBSITE AND TYPE OF PERSONAL DATA COLLECTED

This website is primarily used to provide you with information on the products and services offered by Pharmasal.

When accessing the website, personal data may be collected through the following channels:

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- Personal data collected directly from you to address requests or inquiries

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When reaching out to us through the ‘Contact Us’ forms available within our website, we request the following personal data:

·        Name and surname;

·        Contact number (fixed line or mobile); and

·        Email address.

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We collect your name, surname, contact details and email address through our ‘Contact Us’ form in order to provide you with a personalised response to your inquiries and to be able to contact you to address your requests or inquiries. In responding to your requests or queries, or to provide you with the requested services we may contact you by email or by making use of the fixed line or mobile number provided.

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- Personal data collected directly from you for marketing purposes

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Through the website, you may subscribe to our newsletter or other promotional material by registering your email address and clicking the subscribe button. Once you subscribe we will process your email address for the purpose of sending you our newsletter and / or promotional material.

Through our website we do not collect any special categories of personal data, such as information about your race, religion, health, sexual orientation, or political opinions. We kindly ask you to refrain from providing such sensitive details when submitting the ‘Contact Us’ form. Unless authorised or required by law, we will never store or process any data which is deemed to consist of special categories of data without obtaining your prior written consent.

‍WHAT IS THE LAWFUL BASIS FOR COLLECTING AND PROCESSING PERSONAL DATA?

We collect, store and process your personal data submitted directly by you through the ‘Contact Us’ form to provide you with the best service, and in particular to respond to your requests and inquiries. The lawful basis for processing this information is our legitimate interest in being able to provide effective customer service and support. We ensure that the processing of your personal data is necessary for the purpose of our legitimate interests and does not disproportionately impact your rights and freedoms. Additionally, if we require your personal data for compliance with a legal obligation or to perform a contract with you, we will process your data on these bases.

When responding to your requests or inquiries, we may monitor and / or record communications, including any telephone calls made to or by Pharmasal. Communications may be monitored or recorded in our legitimate interest to enhance the quality of customer services, which is also in your interest.  

When you subscribe to receive our newsletter or promotional material we shall only collect and process your personal data for this purpose and following your consent, which is provided once you subscribe to such promotional material. You may withdraw your consent at any time by sending an email to contactus@springs.mt.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We may share your personal data with the following categories of third parties:

- Group undertakings and third-party IT companies which provide us with IT support services;

- Medical professionals to be able to schedule appointments and respond to your inquiries.

- Legal and other professional advisers and law courts in order to enforce our legal rights, where and if applicable.

SECURITY, STORAGE, AND TRANSFER OF YOUR PERSONAL DATA

We are committed to ensuring that your personal data is secure at all times. We have in place suitable technical and organisational measures to safeguard and secure the personal data we collect, in particular, to protect data against any accidental or unlawful destruction, accidental loss, corruption, unauthorised circulation or access, as well as against any other form of unlawful processing or disclosure to unauthorised persons.

Your personal data will be stored on and processed by our systems and may also be stored on and processed by systems of a third-party data processor(s) appointed by us.  Your personal data is not transmitted or stored outside the EU.  All of our employees and third parties, are contractually obliged to respect the confidentiality of your personal data.  We also ensure that sufficient security measures are implemented by such third parties when collecting, storing and/or transmitting data on our behalf.

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FOR HOW LONG WILL WE RETAIN YOUR DATA?

We will keep your personal data only for as long as we need it for the purpose it is being processed for. In setting retention periods we take into account our business and administrative needs to process your data, as well as, our legal obligations to retain your personal data. We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or administrative purpose for it to be retained.

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WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?

At any point while we are in possession of, or processing your personal data, you have the following rights:

·        Right of access – you have the right to request a copy of the information that we hold about you.

·        Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

·        Right to be forgotten – in certain circumstances, you can ask for the data we hold about you to be erased from our records.

·        Right to restriction of processing – where certain conditions apply you have the right to restrict the processing of your personal data.

·        Right of portability – you have the right to have the data we hold about you transferred to another organisation.

·        Right to object – you have the right to object to certain types of processing.

·        Right to withdraw consent – when we process your personal data based on your consent, for example for the purpose of sending you our newsletter and promotional material, you have the right to withdraw consent at any time.

In addition to the rights listed above, you also have the right to lodge a complaint to the Supervisory Authority, the Information and Data Protection Commissioner (IDPC) by visiting their website at: https://idpc.org,mt.

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HOW TO CONTACT US

If you wish to withdraw your consent to receive promotional material, you may withdraw your consent at any time, by sending an email to contactus@springs.mt.

If you wish to exercise any one of your other rights or have any questions or concerns about this Policy, you are invited to contact our Data Protection Officer (DPO), via email: dpo@vjsalomone.com or by post using the following mailing address:  Data Protection Officer, V.J. Salomone Limited, Upper Cross Road, Marsa, Malta

We endeavour to process your requests within thirty (30) days from receipt and requests will be processed free of charge, unless requests are deemed excessive or unfounded, in which case we may charge a reasonable fee.

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LINKS TO WEBSITES

Our website may feature links to websites operated by our group undertakings as well as social media plugins. These linked sites and social media platforms have their own separate privacy policies. We encourage you to review the respective Privacy Policies of these websites and the privacy statements of the social media platforms when visiting or interacting with them.

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DO WE USE COOKIES?

As do most websites, we make use of Cookies. This Policy also includes our Cookies Policy to explain to what type of Cookies are used and for what purpose.

Cookies are small files that a site or its service provider transfers to your computers hard drive through your Web browser, that enables the sites or service providers systems to recognize your browser and capture and remember certain information. Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. This website uses both persistent and session cookies.

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HOW DO WE USE COOKIES?

We use Cookies to enable us to improve and develop our website to cater for the needs of our visitors and customers, by noting and keeping track of the pages and advertisements visited and how frequently particular pages are visited to identify the most popular areas of our website.

No personal data is collected through the use of cookies. The information collected through the use of cookies is in anonymous form, including the number of visits to this site, how you arrived at the site, and which pages you visited.

In general these are the type of Cookies we use:

STRICTLY NECESSARY COOKIES

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ANALYTICAL COOKIES

We make use of Google Analytics cookies to keep track of the number of visitors to our websites, the time spent on our website and what search engine was used to find our website. The following cookies are used on our website:

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PERFORMANCE COOKIES

Performance cookies typically enable us to see how much traffic we have and to monitor the uptime of our website.

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COOKIE REMOVAL TIPS

The use of Cookies can be blocked from your respective web browser. You can also delete Cookies previously installed from your respective web browser. For more information relating to the use of cookies on websites, including how to block or delete cookies, visit www.allaboutcookies.org. We are also providing you with guidance below, onhow to block or delete cookies when using Internet Explorer, Google Chrome or Mozilla Firefox.

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BLOCKING COOKIES

• If you are using Internet Explorer you can block all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector.
• If you are using Google Chrome you can block all cookies by accessing the “Settings” menu within Google Chrome and then select the “Advanced” settings option. Then switch on the “Send a ‘Do Not     Track’ request with your browsing traffic” option.
• In Mozilla Firefox you can block all cookies by clicking “Tools”, “Options”, and un-checking “Accept cookies from sites” in the “Privacy” box.
• If you would like to block cookies provided     by Google Analytics, you can do so by following the instructions provided     in the following link: https://tools.google.com/dlpage/gaoptout

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DELETING COOKIES

• In Internet Explorer, click on the Tools button and then select the “Delete browsing history” option. Select the     “Cookies and website data” option and click on the “Delete” button.
• In Google Chrome you can delete cookies by accessing the “Settings” menu within Google Chrome and then select the “Advanced” settings option. Select the “Clear browsing history” option.     Select the “Cookies and other site data” tick box and click on the “Clear data” option.
• In Mozilla Firefox, you can delete cookies by, first ensuring that cookies are to be deleted when you “clear private data” (this setting can be changed by clicking “Tools”, “Options” and     “Settings” in the “Private Data” box) and then clicking “Clear private data” in the “Tools” menu.

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CHANGES TO THE PRIVACY AND COOKIES POLICY

We aim to meet high standards and our policies and procedures are, therefore, constantly under review. From time to time we may change or modify this Privacy and Cookies Policy. Accordingly we recommend that you check this page periodically in orderto review our current policies and practices.

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Last modified date: 07 August 2024

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