Latest update: 25 July 2022
1. Identification of the data controller
Arega Pharma Belgium BV/SARL, Laarstraat 16 2610 Antwerp, registered with company number 0722.544.585 (hereinafter ‘Arega’, ‘we ‘ or ‘our’) is committed as a data controller to comply with the applicable legislation on the protection of personal data, including but not limited to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (« GDPR ») as well as any applicable national legislation in execution or follow-up thereof (“Applicable Data Protection Law”).
Notions such as “processing”, “processor”, “controller” or “personal data” shall have the meaning attributed under Applicable Data Protection Law.
Our Sites may include links to other websites over which we have no control. Arega is not responsible for the privacy policies or practices of other websites. We may also link to other websites operated by Arega or Arega’s affiliated companies which operate under the same or separate privacy policies. If you access these websites via our Site, you should review the privacy policies of those sites so you can understand how they collect, use and share your information
2. The personal data we collect, its purpose and legal basis
When you use our Site we may process your personal data as follows :
|Purpose||Categories of personal data||Legal ground|
|To provide you with information on Arega’s business activities, products or services (direct marketing)||Your professional contact details, which may include your name, e-mail address, postal address and contact telephone number;||Consent|
|To respond to your queries or other correspondence you have submitted through the Sites (e.g. email@example.com or contact form)||Your professional contact details, which may include your name, e-mail address, postal address and contact telephone number;||Necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract|
|To analyse the use of our Sites in order to continuously improve content and measure performance||IP address; Web behaviour (in aggregate)||Our legitimate interest, however to the extent that cookies are used for this purpose the applicable legal ground for cookies applies (see below in this schedule)|
|To optimize and tailor the use of our Sites and our communication to you||Web behaviour (in aggregate)||Our legitimate interest to optimize and tailor the use of our Sites and our communication to you|
|To meet legal, regulatory, pharmacovigilance and compliance requirements, in particular to respond to requests for information from government authorities.||This may include your professional contact details, which may include your name, e-mail address, postal address and contact telephone number;||To comply with a legal obligation|
Please note that where the processing of personal data is a legal or contractual requirement, the refusal or inability to provide this personal data may prevent us from providing you with the relevant service or information.
3. Processing of personal data via social media
In addition, we can also process personal data that you share with us via social media platforms. The legal basis that we apply in this case depends upon the situation and context. If you for example request more information about our services via social media, the legal basis that we apply for this use of your personal data is the necessity for the performance of the agreement.
We may also target you through social media, for example to show relevant advertisements or information to you as a Health Care Professional. In the latter case, Arega may be acting as a “joint controller” with the relevant social media platform, in which case you may consider Aregaprivacy@arega.com as your first point of contact for questions or exercise of your rights.
If these processing activities by Arega are done on the basis of cookies, we ask for your prior consent. Please read our cookie polic for more information.
4. Categories of recipients
Your personal data may be shared with:
- authorized staff of Arega (including employees and external consultants), professional advisors and agents with a need to know;
- other functions and affiliated companies in the Arega group of companies:
- Arega Health BV, with registered address at Laarstraat 16, 2610 Antwerp, company number 0721.744.435;
- Arega Medical BV, with registered office at Laarstraat 16, 2610 Antwerp, company number 0728.941.538
- Arega Medical Nederland BV, with registered office at Verlengde Poolseweg 16, 4818CL Breda, KvK number 78212189
- Arega Beheer BV, with registered office at Verlengde Poolseweg 16, 4818CL Breda, KvK number 78207908
- third party service providers which process your personal data on behalf of Arega and who are bound by contractual obligations to keep your personal data confidential and appropriately secure, such as (i) hosting companies (hosting our online platforms), (ii) technology / marketing tool companies (helping us manage our customers and deliver messages), (iii) analytics companies (helping us improve the experience) and (iv) event companies (helping us manage events);
- purchasers, or potential purchasers, of all or part of Arega’s business (and their professional advisors);
- and government authorities, regulatory agencies and law enforcement officials, if required for the purposes specified above, if mandated by law, or if required for the legal protection of our legitimate interests in compliance with applicable laws, including Applicable Data Protection Law.
5. Cookies and related tracking technologies
6. How long we keep your personal data
In accordance with Applicable Data Protection Law, your personal data is retained for as long as we have a legitimate business need to process it, for example the duration of your contract or in case there is no contract for a reasonable period in accordance with our legitimate interests for retention. When we no longer have a legitimate business need to process your personal data, we will either anonymize or delete it or in case this is not possible we will securely store your personal data and isolate it from further processing until deletion is possible.
For more information about the retention periods that apply for the processing of your personal data, please contact us using the contact details in section 9 below.
7. International transfer
In case we transfer your personal data to a third country or international organisation (i.e., outside the EEA), we will make sure that your personal data is either transferred to third countries that are deemed to be offering an “adequate” level of protection by the European Commission (a list of adequate third countries is available on the European Commission’s website), or alternatively, where your personal data is not sent to a country that provides an adequate level of protection, we will put in place appropriate safeguards with the entity receiving your personal data (e.g. the EU standard contractual clauses or binding corporate rules) to ensure that your personal data remains protected in accordance with Applicable Data Protection Law.
If you wish to receive more information or a copy of these safeguards, please contact us at the following e-mail address: firstname.lastname@example.org.
8. Your rights under Applicable Privacy Legislation
In accordance with Applicable Privacy Legislation, you may exercise the following rights:
- The right of access: You have the right to access your personal data and to request a copy of the personal data.
- Right to rectification: You have the right to have incorrect personal data corrected, or incomplete personal data completed.
- Right to erasure: You can request the erasure of the personal data that is being kept about you. The request to erase your personal data cannot always be granted, for example due to contractual or legal obligations.
- Right to object: You have the right to object to the processing of your personal data, for example if the processing takes place on the ground of the legitimate interest or on the ground of the public interest of Arega processing your data. When your personal data is used for direct marketing purposes, you have an absolute right to object to this processing activity.
- Right to withdraw consent: For the processing of your personal data collected by Arega with your consent, you can withdraw your consent at any time. However, the withdrawal of your consent does not apply to processing carried out by AregaPharma prior to your withdrawal.
- Right to restriction of processing: You have the right to obtain restriction of processing in certain situations, for example if you contest the accuracy of the personal data, for a period enabling Arega to verify the accuracy.
- Right to data portability: You have the right to receive the personal data concerning yourself, processed by Arega, in a structured, commonly used and machine-readable format and/or to transmit those data to another controller.
- Right to lodge a complaint: In case of issues, we encourage you to contact Arega in order to reach an amicable solution. However, if you believe an amicable solutions is not possible or desirable, you can use your right to lodge a complaint with the Belgian Data Protection Authority: Gegevensbeschermingsautoriteit, Drukpersstraat 35, 1000 Brussels, Tel +32 (0)2 274 48 00, e-mail: email@example.com.
If processing your request requires unreasonable measures (e.g. it is technically or organisationally almost impossible or extremely costly) then Arega can charge you reasonable compensation in light of the administrative costs involved in fulfilling the request. Arega can also refuse to process requests that are excessive, particularly due to their repetitive nature.
You may exercise these rights by sending an e-mail at the following e-mailaddress: firstname.lastname@example.org. We will respond to your request in accordance with Applicable Data Protection Law.
9. Contact details