Privacy Policy

Privacy Policy

ICG FARMA

PRIVACY POLICY

Last updated: 2023-05-08.

 

  1. GENERAL INFORMATION
    1. Your privacy and the security of your Personal Data are our priorities, and this privacy policy (hereinafter the Privacy Policy) therefore aims to explain how we process and store your Personal Data and what data subject rights you have, as well as to provide other important information about processing of your Personal Data.
    2. The General Data Protection Regulation No. 2016/679 (EU) (hereinafter the GDPR) lays down the main principles and requirements for us and other data controllers in connection with processing of Personal Data. When processing your Personal Data, we adhere to requirements of the GDPR and other applicable legislation as well as instructions given by supervisory authorities.
    3. The term “personal data” (hereinafter Personal Data) used in this Privacy Policy corresponds the definition provided in the GDPR and, inter alia, means any information or information set based on which we can either directly or indirectly identify you, e.g. your name, surname, e-mail address, telephone number, etc.
    4. This Privacy Policy shall apply when you acquire any medicinal products distributed and sold by us (hereinafter the Products), communicate with us, order and use our services, use and visit our website at icgfarma.eu (hereinafter the Website), as well as contact us by telephone or via other channels.
    5. This Privacy Policy shall also apply when we, as the Product registrant, in the process of performing pharmacovigilance requirements laid down in legislation, process Personal Data in order to ensure investigation of an adverse reaction to a Product as well as contact you to obtain further information about the adverse reaction that you notified, compare information about the adverse reaction to information available to ICG Farma about other adverse reactions in order to investigate the safety of a Product series, a specific Product or an active substance, as well as provide mandatory reports to the State Medicines Control Agency or the EudraVigilance database so that they can investigate safety of a Product series, a Product or an active substance in comparison to reports from other sources.
    6. We would like to draw your attention to the fact that the Website may contain links to other websites or social media accounts. This Privacy Policy shall not apply to any such websites or social media accounts and, prior to providing your Personal Data on any of these websites or social media accounts, please consult their privacy policies.
    7. If you use our Website, order and use our services, acquire the Products, or provide information about any adverse reactions that affected you or other persons, we deem that you have read and familiarised yourself with the information contained in the Privacy Policy about processing of your Personal Data and purposes, methods and procedure of use of your Personal Data.
    8. We may amend the Privacy Policy, and we therefore ask you to visit the Website on a regular basis and consult the latest published version of the Privacy Policy. In certain cases, we can provide you with separate privacy notices relating to certain services that we provide. Any such notices must be read together with this Privacy Policy.

 

  1. WHO ARE WE?
    • We are UAB ICG Farma, a private limited liability company incorporated in the Republic of Lithuania, Company Reg. No. 302244351, registered address: Ukmergės Str. 369A, LT-12142 Vilnius (hereinafter ICG Farma or we), and we are a controller of your Personal Data. ICG Farma acts as a data controller to the extent processing of your data is related to provision of services to you, acquisition of the Products from us, assurance of functioning of the Website, etc.
    • A data controller decides the purpose for which Personal Data are processed and in what manners they are processed. A data processor only processes Personal Data on behalf of a data controller and for the purposes and in the manners defined by the data controller. Where ICG Farma acts as a data processor, data processing matters and related rights and obligations of ICG Farma are laid down in the respective data processing agreement.

 

  1. HOW DO WE RECEIVE YOUR PERSONAL DATA?
    • We process your Personal Data that we receive in the following manners:
      • Information that you provide when ordering services and the Products and when you contact us by e-mail or telephone, etc.;
      • Information that you or third parties provide in connection with an adverse reaction to a Product that you or another person had;
      • Information about your use of the Website, e.g. history of use of services, your IP address, history of visits to the Website, selections, opened URL links, etc.;
      • We collect information using a variety of technologies such as cookies and app interfaces, including when you use the Website, use one or more devices, regardless of whether you are logged in or not.
    • We adhere to the provision that a person who provides Personal Data to us, both when he or she provides his or her Personal Data and Personal Data of other persons, is responsible for the accuracy, completeness and relevance of such Personal Data and, if required, for the consent of the person whose data are provided to the provision of that person’s Personal Data.

 

  1. WHAT PERSONAL DATA DO WE PROCESS AND FOR WHAT PURPOSES AND ON WHAT LAWFUL BASES DO WE PROCESS THEM?
Purpose of processing of Personal Data Personal Data processed Term of processing of Personal Data Lawful basis for processing of Personal Data
Legislation regulating pharmacovigilance require comprehensive records of each adverse reaction to a Product that is notified to us. This enables evaluating the instance and comparing it to other adverse phenomena relating to a specific Product or Product series.

 

In order to fulfil these legal requirements, we have to process your Personal Data, including special categories Personal Data.

 

 We can collect the following information about you:

 

Your initials or given name and surname, age, date of birth, sex, weight, and height;

 

Information about the Product that provoked an adverse reaction: taken or prescribed doses, reason for Product intake or prescription, and any subsequent changes in your standard treatment;

 

Information about any other medicines or products being taken or taken during the adverse reaction: taken or prescribed doses, duration of medicine intake, reason for medicine intake, and any subsequent changes in your standard treatment;

 

Information about the adverse reaction that you encountered, treatment used for treating the reaction, and any long-term effects that the reaction had on your health condition;

 

Other medical information, e.g. laboratory reports, medical and patient history.

 

Some of the listed categories of Personal Data, e.g. health data, qualify as special categories Personal Data.

 We will process your Personal Data for the purpose referred to until the Product remains registered and 10 years afterwards. Performance of a legal obligation (Article 6(1)(c) of the GDPR).

Article 55(1) of the Law on Pharmacy of the Republic of Lithuania.

 

Order No. V-185 “Regarding approval of the procedure of submission of a health care or pharmaceutical specialist report on a suspected adverse reaction (SAR), the form of the health care or pharmaceutical specialist report on a suspected adverse reaction (SAR), and the form of the patient report on a suspected adverse reaction (SAR)” of 20 February 2013 of the Ministry of Health of the Republic of Lithuania.

 

Order No. (1.4) 1A-107 “Regarding approval of the description of requirements for the pharmacovigilance system of a medicinal product registrant”

of 4 February 2014 of the State Medicines Control Agency under the Ministry of Health of the Republic of Lithuania.

 

Personal Data of special categories must be processed for reasons of public interest in the area of public health (Article 9(2)(i) of the GDPR).

 
In order to fulfil the pharmacovigilance requirements according to legislation, we also have to process your Personal Data, if you notify about an adverse reaction to a Product encountered by another person. Your given name, surname, e-mail address, telephone number, address, and occupation (this information may be required to select questions about an adverse phenomenon, depending on your possible medical knowledge).

 

Your relationship with the person whose adverse reaction you notify.

 

 We will process your Personal Data for the purpose referred to until the Product remains registered and 10 years afterwards. Performance of a legal obligation (Article 6(1)(c) of the GDPR).

 
Conclusion and performance of a contract for provision of services and/or supply (sale) of a Product. Your given name, surname, e-mail address, telephone number, address and/or Product delivery address, name and address of the represented legal person, job title and (or) relation to the represented legal person, and content and notifications relating to an order of the Products and services. We will process your Personal Data during the term of the contract and for 10 years from expiry of the contract. Performance of a contract with you or seeking to take actions at your request prior to concluding a contract (Article 6(1)(b) GDPR);

 

Our or a third party’s legitimate interest to perform obligations in a quality and effective manner (Article 6(1)(f) of the GDPR).
Management of the Website, assurance of security of the Website, and improvement of the quality of the Website.

 

 IP address, data collected by means of cookies, unique mobile device user number, and other settings, data about the device used (model, operating system, browser type and version), unique device identifier (e.g. IMEI of your device, MAC address of the wireless interface of your device or the mobile telephone number used by your device), mobile network information, analytical data, e.g. information about your visits, including any links on which you clicked on our Website (through it and from it; including date and time), views or services searched, page response time, time spent on certain pages, page interaction information (e.g. scrolling and clicks) and methods used to exit the page. The Website data are stored in the manner specified in the “Cookies and other monitoring technologies” section of this Privacy Policy.

 

Any data that are not included in the monitoring technology information are stored for up to 3 years from the date they are collected.

 Your consent to processing of Personal Data (Article 6(1)(a) of the GDPR);

 

Our legitimate interests or legitimate interests of a third party (Article 6(1)(f) of the GDPR).

 

 

  1. HOW DO WE USE YOUR PERSONAL DATA AND WHAT PRINCIPLES DO WE FOLLOW?

 

  • We only collect and process Personal Data that are required for achieving the purposes of processing of Personal Data specified by us.
  • In the process of processing your Personal Data, we adhere to requirements of applicable legislation, including the GDPR:
    • We collect your Personal Data for set, clearly defined and lawful purposes and do not process them for any purposes incompatible with them;
    • We process your Personal Data in a lawful, fair and transparent manner;
    • We implement all reasonable measures to ensure that any Personal Data that are inaccurate or incomplete, with consideration of the purposes of their processing, are immediately rectified, supplemented, that their processing is suspended, or that they are destroyed. You have the right to adjust and update your information that you provide to us. In certain cases (e.g. to be able to provide services or Products compliant with your needs or to be able to appropriately perform pharmacovigilance requirements), we need to have accurate, up-to-date information relating to you, and for this reason we may request that you from time to time confirm that the information that we have about you is accurate;
    • We store personal data in such a form as to ensure that your identity can only be established for a term not longer than necessary for the purposes for which the Personal Data are processed;
    • We do not provide any Personal Data to third parties and do not disclose them in any manner other than indicated in the Privacy Policy or other our publicly available documents;
    • We assure that your Personal Data are processed safely and are protected against loss, unauthorised use, and alterations. We have implemented physical and technical measures to protect any information that we collect against accidental or unlawful destruction, damage, alteration, loss, disclosure as well as against any other unlawful processing. The Personal Data security measures that we use are implemented with consideration of the risks that are encountered in the process of processing of Personal Data.
    • Our employees have undertaken in writing to not disclose or provide your Personal Data to any third parties.

 

  1. TO WHOM AND WHEN DO WE PROVIDE YOUR PERSONAL DATA?

 

  • We will only provide your Personal Data to any other data controllers or processors in the manner defined in this Privacy Policy.
  • Pursuant to legislation regulating pharmacovigilance, we must provide information and Personal Data to the State Medicines Control Agency and/or the European Medicines Agency. Your Personal Data provided to ICG Farma are stored in databases on servers located in Lithuania. These servers are owned and supervised by ICG Farma and/or service providers hired by ICG Farma. Personal Data are not provided to any third country.
  • In the process of adhering to pharmacovigilance requirements, we have to review the general trends of reports received in each country to which we sell our Products. The analysis is carried out by an authorised pharmacovigilance officer of ICG Farma. To fulfil these requirements, ICG Farma sends any information provided in reports on a suspected adverse reaction to the EudraVigilance database. Related Personal Data may be forwarded to the EudraVigilance database. Personal Data are transmitted, to the maximum extent possible, in a depersonalised and/or minimised form, e.g. without transmitting a person’s given name and surname and only transmitting initials.
  • We can provide Personal Data to other pharmaceutical companies in the European Union, which are partners of ICG Farma, in the process of implementing joint marketing and distribution, and to licensed partners in cases where requirements of pharmacovigilance legislation provide for such medicines’ safety information exchange. If ICG Farma transfers any Personal Data to its partners, these data will be depersonalised to the maximum extent possible, i.e. provided in a form that does not permit identifying you directly. ICG Farma will in no instance disclose any collected data for commercial or marketing purposes.
  • Personal Data can be transferred to a third party, e.g. a health care service provider, if it is compulsory pursuant to enforced legislation, by a court order or an instruction of a State authority official, or if such disclosure is required in the process of a criminal or other legal investigation or court proceedings in Lithuania or abroad (in the European Union).
  • We can transfer your Personal Data to our partners or consultants, e.g. providers of services of server hosting, data centres, cloud, maintenance, IT, payment, audit and accounting, legal, tax consultancy, loss administration, debt recovery, and shipment delivery. We require from data processors to store, process and treat Personal Data in the same responsible manner as we store, process and treat them and only in accordance with our instructions.
  • We develop and improve the Website and our services in order to ensure the safety and confidentiality of any Personal Data that we process and be able to ensure the availability and functioning of the Website and our services. For this reason, we transfer your Personal Data to service providers that provide cloud and hosting services, IT security, maintenance and technical services, and communication services.
  • Pursuant to applicable legislation, we provide data to law enforcement and pre-trial investigation authorities, courts, and other dispute resolution institutions, State or municipal entities and institutions, and other parties that perform functions prescribed by the law. We provide these entities with information prescribed by legislation or as required by these entities.
  • If required, we provide data to companies that intend to purchase or actually purchase the business of ICG Farma or implement a joint activity with us, or cooperate with us in any other manner, as well as to any companies that we incorporate.

 

  1. WHAT RIGHTS DO YOU HAVE?

 

7.1.

 

Your right What it means
The right to be informed

 

 We inform you about processing of your Personal Data in this Privacy Policy, which we publish on the Website. In certain cases, to provide you with more details on how we process your Personal Data, we can provide separate informational notices to you.
The right to access your Personal Data that we process You have the right to request a copy of your Personal Data that we process. There are certain exceptions, e.g. when we have to take into account other persons’ rights, which means that you cannot always receive all your Personal Data that we process.
The right to rectification of Personal Data You have the right to request that we rectify any information that, in your opinion, is inaccurate. You also have the right to request that we supplement any information that, in your opinion, is incomplete.
The right to restrict processing of Personal Data In certain circumstances, you have the right to request us to restrict processing of your Personal Data. This means that your data may be used for certain purposes, e.g. for assurance of our legal claims or for implementation of our rights.
The right to disagree to processing of data You have the right to disagree to processing of your Personal Data, if we process them based on our legitimate interest. If you express your disagreement, we will only be able to continue to process your Personal Data for justifiable lawful reasons, which prevail over your interests, rights and freedoms, or in order to present, enforce or defend legal claims.
The right to Personal Data portability In certain circumstances, you have the right to request that we transfer any Personal Data that you provided from our organisation to another organisation or provide relevant information to you. This only applies in respect of Personal Data that you have provided. This right will only be implemented in case where the respective bases and measures exist that assure that no threat is posed to any other persons’ data as a result of portability of the requested Personal Data.
The right to withdraw your consent to data processing

 

 You have the right to withdraw your consent to processing of your Personal Data, when these data are processed or are intended to be processed for direct marketing purposes, including profiling to the extent it is related to such direct marketing (based on any Personal Data provided by you, profiling may be implemented for the purpose of direct marketing in order to provide customised offers to you. You can, at any time, withdraw your consent to processing of your Personal Data in an automated manner, including profiling, or to disagree to such processing).

 

  • Implementation of the rights:
    • If you want to avail of any of your rights referred to above, you can e-mail us to info@icgfarma.eu;
    • For security reasons, in certain cases we will be unable to satisfy your applications without first establishing your identity; this means that we can request you to provide proof of your identity, e.g. your ID document or other information. Upon receipt of an application by e-mail and with consideration of the content thereof, we can request you to provide an application signed with a qualified electronic signature and send it to us, or visit us;
    • We normally do not charge any fee for implementing your rights. Yet legislation permits us to charge a reasonable fee or refuse to satisfy your application, if it is evidently unjustified or excessive;
    • If you do not want that your Personal Data be processed for direct marketing purposes, contest or survey purposes, including profiling, you can disagree to such data processing without indicating any reason for such disagreement by e-mailing to info@icgfarma.eu or notifying us in another manner indicated in the respective notice (e.g. by clicking on the respective link in a newsletter);
    • Upon receipt of your application or instruction on processing of Personal Data, we will, within 1 month from the date of the application, provide a response and perform the actions indicated in the application or notify you of the reasons for which we refuse to perform them. With consideration of the complexity and number of applications, the specified term may be extended for another 2 months. In this case, we will notify you about such extension within 1 month from receipt of your application.

 

  1. COOKIES AND OTHER MONITORING TECHNOLOGIES

 

  • A cookie is a small text file that a website that you visit saves on your computer or mobile device. Thanks to a cookie, a website can “remember” your actions and choices (registration name, language, font size and other display settings) for a certain time, and you do not need to enter them again every time you visit the website or browse its individual webpages. Other technologies, including data that we store on your browser or device, identifiers relating to your device and other software, can be used for similar purposes. Cookies are widely used to ensure operation of websites and an improved and more effective operation of websites. In this Privacy Policy, all the technologies referred to above shall be called “cookies.”
  • We use cookies to analyse information flows and user behaviour, promote trust and ensure security as well as to ensure the appropriate operation of the Website and its improvement, and remember your chosen settings.
  • You may choose whether you want to accept cookies or not. If you do not agree that any cookies are saved on your computer or other device browser, you can indicate this in the consent to the use of cookies, change settings of your browser, and deactivate cookies (all at once, or individually, or in groups). If you want to reject cookies on your mobile device, you have to follow the official guidelines applicable to your device. Please note that in certain cases turning cookies off may lead to slower browsing, restrict operation of the Website and certain functions, or block access to the Website.
  • Detailed information is provided at http://www.AllAboutCookies.org or https://www.google.com/privacy_ads.html. You can turn off use of third-party cookies for advertising-related purposes by visiting the website of the Digital Advertising Alliance at https://optout.aboutads.info/?c=2&lang=EN.
  • We can use essential cookies that are required for ensuring operation of the Website, analytical cookies, functional cookies that are intended to analyse visits to the Website, remember visitor choices and customise them for the Website, so that we are able to provide improved functions, productivity cookies, third-party cookies, and advertising cookies that are intended to display personalised and general advertising to you.
  • The following cookies are used on our Website:
Purpose of cookie Name of cookie

 

 Validity term

 
Cookies consent status AMP-CONSENT 1 year
Cookies consent status wp_gdpr_cookie_preferences 1 year
Used for generating statistical data when visitors use the website _ga 2 years

 

  1. CONTACT US

 

  • If you have any questions relating to this Privacy Policy or your Personal Data, you can contact us at any time using the contact information provided below:

 

E-mail: info@icgfarma.eu  

Address: Ukmergės Str. 369A, LT-12142, Vilnius.

 

  • If you have any comments or would like to file a formal complaint on how we process your Personal Data, please e-mail to the e-mail address specified above and provide as much information as possible. We will cooperate with you and will seek to resolve any issues promptly.
  • Furthermore, you can file a complaint to the supervisory authority―the State Data Protection Inspectorate. Further information and contact details are available on the Inspectorate’s website (https://vdai.lrv.lt/). We seek to resolve any disputes promptly and amicably, and we therefore encourage you to contact us first.