Privacy policy

Last update: October 2023

Almirall Limited (“Almirall”, “we”, “us”, “our”) is committed to protecting and respecting your privacy.

This Privacy Statement (together with our Terms of Use, our Cookie Policy and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us on a voluntary basis, will be processed by us.

For the UK & Ireland Drug Safety Privacy Statement click here

For the Interactions with Healthcare Professionals Privacy Statement click here

1. Basic information

2. Additional information

2.1. WHO IS THE CONTROLLER OF THE DATA YOU PROVIDE?

The data controller is Almirall Limited, addressed at Harman House, 1 George Street, Uxbridge, Middlesex, UB8 1QQ registered in England and Wales: company number 6320852.

For more information about this document or how we process your personal data, you may contact our Global Data Protection Officer at the e-mail address dpo.global@almirall.com.

You may also contact us at +44(0)2071602500.

If you are based in the EU and have any questions about our privacy statement, your rights regarding your personal data, or how we use your personal data, please do not hesitate to contact our appointed EU representative, Symmetry Solutions Ltd, at:

- Email: almirall@symmetrygroup.ie

- Post: FAO Almirall EU Rep, Symmetry Solutions Ltd, The Tara Building, 11-15 Tara Street, Dublin 2, D02RY83, Ireland.

2.2. WHICH KIND OF PERSONAL DATA WE PROCESS?

We may collect and process the following data about you:

• a) Information you give us. You may give us personal data through enquiry forms available on the Site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide to us for the following purposes:
  • a. Reporting an adverse event
  • b. Medical information enquiries.
  • c. General enquiries related to e.g., media, investors, R&D activities, partnering with Almirall and job opportunities enquiries.
  • d. If you are a Supplier or a Partner of Almirall, we may process your personal data to manage our relationship and contracts with you and/or to check whether there is any conflict of interest or to ensure compliance with legal requirements or with our policies. You can find more information in our Suppliers portal and in our Partners portal.

We try to only collect the necessary information to process your requests and reports. The information you give us may include, among others, your full name, address, e-mail address, country, and phone number.

In relation to drug safety, we may contact you to follow up on any particular case reported.

• b) Information we collect about you. When you visit our Site we may automatically collect the following information:
  • - Using cookies: Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, and language preferences. We and our service providers use the information for security purposes, to facilitate navigation and to display information more effectively. We also use cookies to recognize your computer or device, which makes your use of the Site easier and makes the Site display properly on your device. In addition, we use cookies to gather statistical information about Site usage in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it. Some of our cookies are managed for us by third parties. You can refuse to accept these cookies by following your browser's instructions; however, if you do not accept them, you may experience some inconvenience in your use of the Site. To learn more about cookies, please take a look to our Cookies Policy
  • - Through your browser: The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are: browser type and browser version, operating system used, deferrer URL, host name of the accessing computer, time of the server request and IP address.Through your browser: The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are: browser type and browser version, operating system used, deferrer URL, host name of the accessing computer, time of the server request and IP address

These data are not combined with other data sources.

The provision of your personal data is voluntary (except where expressly stated). However, missing or incorrect mandatory personal data may make it impossible for Almirall to provide the information you have requested.

2.3. WHAT USES ARE MADE OF YOUR INFORMATION?

We use your personal data in the following ways:

• a) Report an adverse event (Drug Safety): The personal contact data provided will be kept in order to obtain, or to follow-up information relating to the adverse event case. All pharmacovigilance activities are conducted in compliance with our legal obligations with the Competent Authorities in the field. Please check our UK & Ireland Drug Safety Privacy Statement for more details. for more details.
• b) Medical information: we may collect your personal data in order to respond to your enquiries as part of our obligations as a pharmaceutical company.
• c) General enquiries: we may collect your personal data to answer your enquiries regarding e.g., Almirall services, media, R&D activities, job opportunities and partnering with Almirall, or to receive your feedback.General enquiries or feedback in relation to other matters: to solve your enquiries in relation to media, R&D activities, job opportunities and partnering with Almirall, or simply to receive your feedback.
• d) Relations with our Partners and Suppliers: The personal data we process from our partners or suppliers is generally limited to contact information (name, name of the organisation, phone, email and other contact details) and financial information (payment-related information). In addition, we may also process some data to check whether there is any conflict of interest or to ensure compliance with legal requirements or with our policies.
• e) Site maintenance: Part of the data is collected in order to ensure error-free provision of the Site and improve the services offered through the Site.

Your personal data will not be used for any other different purposes.

2.4. HOW LONG DO WE STORE YOUR INFORMATION FOR?

The personal data you provide to us will be securely stored and processed as follows:

• a) Drug Safety: Where personal data has been provided by you in relation to an adverse event, after the maximum period of one (1) year following the completion of the case, your data will be made unidentifiable. This data in redacted form will be stored securely in line with legal requirements to which Almirall is subject, during the commercial life of the product plus 10 years. See more detail in the UK & Ireland Drug Safety Privacy Statement.
• b) Medical Information: Your personal data will be kept for a period of time following the provision of a response for quality assurance purposes. After a maximum period of one (1) year following the provision of a response your personal data will be made unidentifiable. Medical Information: The personal data provided will kept for the time necessary in order to resolve your enquiry.
• c) General enquiries: Your personal data will be kept for a period of time following the provision of a response for quality assurance purposes. After a maximum period of one (1) year following the provision of a response your personal data will be made unidentifiable.
• d) Relations with Partners or Suppliers: We will only retain Suppliers’ personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal or regulatory requirements. When this period expires, your personal data will be removed from our active systems.
• e) Site maintenance: Part of the data is collected in order to ensure error-free provision of the Site, keep the Site safe and secure and improve the services offered through the Site to ensure content is presented effectively for you and your computer. The data retention period of the personal data you provide to us through the use of cookies is explained in our Cookies Policy.

2.5. WHICH IS OUR LAWFUL BASIS TO PROCESS YOUR PERSONAL DATA?

The reasons why we use your personal data (indicated in section 2.3) are the following:

• a) Drug Safety: We have a legal obligation relating to pharmacovigilance, cosmetovigilance and materiovigilance. Drug safety: We have a regulatory obligation in pharmacovigilance and cosmetovigilance and it also pursues an aim of public interest in the area of ​​health.
• b) Medical information: As a pharmaceutical company, we have a legitimate interest to respond to your enquiries and provide information about our products.
• c) General enquiries: your consent.
• d) Relations with Partners and Suppliers: depending on the circumstances, the processing can be based on the execution of a contract to which the data subject is party in case on an individual, or in our legitimate interest of conducting business with our partners and suppliers. Processing may also be necessary for compliance with a legal obligation to which Almirall is subject, as well as our legitimate interest or public interest in safeguarding any conflict of interests or to conduct investigations to avoid bribery or other illegal practices. Provide you access to specific materials or information: your consent
• e) Site maintenance: Almirall’s legitimate interest to provide you with the site without errors In relation to the information we gather through cookies from a technical perspective, we have a legitimate interest to manage the Site. Other Cookies used for statistical purposes or to acquire an aggregate overview of our visitors shall be subject to consent, without making any predictions or drawing any conclusion about an individual. You can also visit our Cookies Policy for more information.

2.6. WHO DO WE SHARE YOUR INFORMATION WITH?

With the exception of a legal obligation, your data will not be shared with third parties other than our services providers who are contracted by us to deliver services, such as responding to your information requests.

Whenever information needs to be transferred to Recipients outside the United Kingdom or the European Economic Area, to a country which has not received the decision of an adequate level of protection issued by the European Commission and/or the United Kingdom, personal data shall be duly protected by adequate safeguards, such as Standard Contractual Clauses approved by the European Commission and/or UK Addendum, or binding corporate rules of the data processor, Where necessary, any other adequate safeguards and supplementary measures may be adopted.

2.7. WHAT ARE YOUR RIGHTS AS DATA SUBJECT AND HOW YOU CAN EXERCISE THEM?

You may exercise at any time any of the following rights:

• a) Right of access: you can obtain access to your information
• b) Right to rectification: you are entitled to have your information corrected if it is inaccurate or incomplete.
• c) Right to erasure: you can request the deletion or removal of the information concerning yourself where there is no compelling reason for an organisation to keep using it. This right is also known as "the right to be forgotten".
• d) Right to restrict processing: you can ‘block' or suppress further use of your information in certain circumstances. When processing is restricted, we may still store your information, but will not use it further.
• e) Right to data portability: you can obtain and reuse your personal data for your own purposes across different services with a different data controller. If you request the direct transfer of the data to another data controller, this will only take place if it is technically feasible.
• f) Right to object: you can object to certain types of processing, in certain circumstances.

The lawfulness of any data processing up to your consent withdrawal remains unaffected by the revocation.

These rights may be limited in some situations – for example, where we can demonstrate we have a legal requirement to process your personal data.

If you would like to exercise any of the rights listed above, you can send us an electronic request to the following contact address.

Additionally, you can contact the Information Commissioner's Office (ICO) www.ico.org.uk for any claim related with the use of your personal data. If you are an EU citizen, you can contact your national Supervisory Authority for any claim related with the use of your personal data. You can find a list of the EU national Supervisory Authorities following this link: Our Members | European Data Protection Board (europa.eu)