Dear Healthcare Professional,
A. Menarini Diagnostics Srl takes your privacy very seriously and it is committed to adopt the sector’s highest standards. For this reason, we would like to provide you with updates on how A. Menarini Diagnostics Srl (also The "Company" or "we") processes your personal data in accordance with Regulation 2016/679/EU ("Regulation").
1. WHY WE PROCESS YOUR DATA
We may use the personal data that you voluntarily provide (such as your first name, last name and contact details) at conferences, workshops, seminars, (e.g. where you may have provided us with your business card or filled out one of our contact forms) or that have been collected by event organizers (e.g. where you have consented to such organizers providing such contact information to exhibiting companies), to establish an initial contact with you and/or to send you the materials on our products/services you were interested in. This initial contact is made on the basis of the Company's legitimate interest in establishing and maintaining business contacts, if said contact with you is via phone or face to face visit (pursuant to Article 6.1.(f) and recital 47 of the Regulations) or your consent if said contact with you is via email (pursuant to Article 6.1 (a) of the Regulation).
After you have shown an interest in receiving an email or a phone call, we will share your Data with the A. Menarini Diagnostics affiliate based in your country.
The complete list of A. Menarini Diagnostics affiliates is accessible at the following link:https://www.menarinidiagnostics.com/en-us/Home/About-us/Global-Presence
If there is an interest in pursuing such contacts, your Data will be entered in the systems of the concerned A. Menarini Diagnostics affiliates, and processed as described in the information notice for HCPs that you will receive during the first visit/contact with the Sales Representatives of the concerned A. Menarini Diagnostics affiliate or within 30 days after your Data is received by your country’s A. Menarini Diagnostics affiliate.
2. WHAT DATA WE PROCESS
In order to establish an initial contact with you and/or send you the materials on our products/services you were interested, we need to process the data that you voluntarily provide or that you have authorized the event organizers to provide to us, such as: first name, last name, email, phone number, Health Care Organisation, contact channel preferences, acknowledge of Menarini products, etc collectively the “Data”.
In addition, we may process your Data in order to comply with legal obligations, regulations and EU legislation, to assert or defend rights in court, to enforce the Menarini Group Code of Conduct, to pursue other legitimate interests (e.g. sharing of data between companies of the Menarini Group of which A. Menarini Diagnotics srl is part) and in all cases provided for in Articles. 6 and 9 of the Regulation, where applicable.
3. HOW WE PROCESS DATA
The Data will be processed in paper and electronic form in compliance with applicable regulations, including security and confidentiality profiles and inspired by the principles of correctness and lawfulness of processing. Data will be kept for the period of time strictly necessary to achieve the purposes for which they have been collected; in any case, the criterion used to determine this period of time is based on the respect of the terms allowed by the applicable laws and the principles of minimization and rational management of the archives. For the purposes specified above, we may retain some data even after our activities with you have ceased for the time necessary to fulfil contractual or legal obligations. We update and maintain our databases so that the Data is always correct and accurate.
4. WHO MAY HAVE ACCESS TO THE DATA
The Data may be processed by our employees belonging to the categories of administrative staff, sales representatives and product managers and other subjects who need to process them in the performance of their duties. For activities of an organizational, administrative, financial and accounting nature, in accordance with Articles 6 and 9 and Recitals 48 and 52 of the Regulation, the Data may be communicated to other companies of the Menarini Group, also in non-EU countries (hereinafter "Third Countries") for the purpose stated above under point 1. Pursuant to the laws and regulations to which we are subject, we may have to communicate the data to Health Authorities and other health or university bodies, to other Authorities and associations also in Third Countries as well as to legitimate recipients under the law and regulations. Furthermore, in relation to the above mentioned purposes and fulfilments, the Data may be communicated to third party companies, such as suppliers, sub-suppliers, providers of IT and "Cloud Computing" services, agencies and organisational secretariats, professional studios and companies that carry out fiscal or administrative activities on our behalf also in Third Countries. As the case may be, these entities will act as Data Controllers or Data Processors for the same purposes as indicated above and in accordance with applicable law. As regards the possible transfer of Data to Third Countries, including countries that may not guarantee the same level of protection provided by the applicable law, we inform you that the processing will take place only on the basis of one of the modalities allowed by the applicable law, such as, for example, your consent, the adoption of Standard Clauses approved by the EU Commission, the selection of subjects adhering to international programs for the free movement of data or operating in countries considered safe by the EU Commission.
5. WHO IS THE DATA CONTROLLER
The processing operations for the purposes indicated under point 1 of this information notice are carried out by A. Menarini Diagnostics S.r.l. as Data Controller.
6. HOW TO EXERCISE YOUR RIGHTS
By contacting the Data Protection Officer of the Menarini Group (dpo at menarini dot com - please replace "at" with "@" and "dot" with ".") or A. Menarini Diagnostics srl at the following email address email@example.com you will be able to know the updated list of the persons in charge of data processing, as well as exercise the rights recognized by art. 15-22 of the Regulation, including: knowing whether or not any Data referring to you is being processed by us; access your Data; verify the Data’s content, origin, exactness, location (including, where applicable, the Third Countries where the data might be); obtain a copy of the Data; ask that the Data are supplemented, updated, amended; in the circumstances set forth by the law, ask that the processing of Data is restricted, that Data are deleted, anonymised, frozen; oppose to direct contact activities (including restricting contact methods to specific communication media), oppose to the processing of Data for legitimate reasons. Likewise, you may notify the Menarini Group’s Data Protection Officer any observations you may have on our use of your Data which you consider inappropriate and/or lodge a complaint to the Authority for the Protection of Personal Data.