PRIVACY POLICY

We attach great importance to the protection of your personal data and privacy rights on the Internet. Please read our privacy policy to better understand how we treat your personal information, what information we store and how we use it.

1. INFORMATION ABOUT PROCESSING AND PROTECTION OF PERSONAL DATA

1.1 The protection of your personal data is very important to us, therefore we always proceed in accordance with applicable laws and international standards.

1.2 This communication on the adoption of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46 / EC (GDPR) with effect from May 25, 2018, applies to the processing of your personal data by ACTANDO SA, Identification number CH-217.3.552.804-2, 7 Rue Jean Petitot 7 Case postale 1393 1211 Genève 1 – Switzerland (hereinafter referred to as “the Company” or “we” ). We provide a summary of the basic information on the processing and protection of your personal data by the Company below.

1.3 This Privacy Policy applies to all of our Web sites (www.actando.comwww.actando.cnwww.actando.es, www.actando.ruwww.pharmacademy.comwww.nrjacademy.comwww.simpactdetailing.comwww.medeviceacademy.comwww.promotiondesmedicaments.fr) and our Services. This Privacy Policy governs our data collection, processing and usage practices. It also describes your choices regarding use, access and correction of your personal information. Use of our websites and services signifies your agreement with the data practices described in this Privacy Policy.

2. PERSONAL INFORMATION WE PROCESS AND HOW WE COLLECT IT

2.1 Personal data we process about you and its scope differs, in particular, by purpose and services provided:

2.1.1 For the purposes of contract management, closure and implementation:

(a) Identifying information (first name, surname, address)
(b) Contact details (e-mail, phone number)
(c) Company name, identification number, registered office (if you are an entrepreneur).

2.1.2 In order to improve our services and offerings

(a) Information on visiting our website (cookies, IP address)
(b) Data about your purchasing habits and the use of our services, such as the date, price, and name of the services used, including related communication with you.

2.1.3 For marketing purposes incl. sending business messages and personalizing advertising

(a) Information on visiting our website (cookies, IP address)
(b) Information on visiting our website (cookies, IP address)
(c) Information about your purchasing habits and the use of our services, such as the date, price, and name of the services and products used, including related communications with you.

2.2 We obtain personal data directly from you (especially when entering into a contract and during a contractual relationship), on the basis of your visits to our website (see the cookies section below) or the registration forms you have filled in.

3. HOW WE USE YOUR PERSONAL INFORMATION

3.1 We use your personal information for the following purposes:

(a) to conclude the contract and execute your order;
(b) communicating with you and managing our contractual relationship;
(c) analyzing, evaluating and improving our customer service;
(d) resolving your complaints and complaints;
(e) the fulfillment of our legal obligations; and
(f) to inform about changes and innovations in the products and services provided and our personalized offers.

3.2 If it is necessary for the conclusion and performance of the contract or for the protection of our legitimate interests related to the conclusion or fulfillment of the contract, upon your consent or if permitted by legislation that also provides for the protection of your rights, we use technology especially for the creation of your customer profiles for the above purposes.

3.3 We retain your personal data only for as long as any of the above-mentioned processing purposes takes place and then only for a period and under terms and conditions in accordance with applicable legal regulations.

3.4 If consent is granted for marketing purposes (including profiling for the purpose of offering good goods and services and processing cookies), this period shall be 3 years from the grant of the consent, its renewal or the creation of our legitimate interest. In other cases, the processing time is the result of processing or is provided by law.

4. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

4.1 The legal basis that enables us to process your personal information depends on the purpose for which we process the personal data. We can therefore process your personal information in your specific case without your consent because:

(a) it is necessary for the purpose of concluding or performing a contract with you;
(b) it is necessary to meet our legal obligations (accounting and taxation);
(c) it is necessary for the protection of our legitimate interests (in connection with the application of the claims of concluded contracts or in connection with the analysis and improvement of our services);

4.2 With your consent, we may process your personal data for marketing purposes, that is, our product offerings, newsletters, or other business communications by sending to your email address and using personalized marketing and remarketing. You may at any time revoke your consent to the use of your personal information by sending us your notice of withdrawal to our email privacy@actando.com or by writing to the above address of the Company.

5. TO WHOM WE PROVIDE YOUR PERSONAL INFORMATION

5.1 We may provide your personal information:

(a) service providers who provide us with services related to our activity, especially carriers, agents of your payments, persons helping us with the administration of the contracts and your claims for performance or who print and deliver documents;
(b) Service Providers assisting us with the proper functioning, optimization, security, and site settings;
(c) those who work with us to create and mediate our services
(d) service providers helping us to share information about our innovations and services
(e) to other persons in accordance with applicable law (notification to tax authorities in cases specified by law, police in criminal investigation, etc.).

5.2 Your personal data may be transferred and stored within the countries of the European Economic Area (EEA) as well as entities located outside the EEA which include ensuring their compliance with EU-US Privacy Shield.

6. WHAT ARE COOKIES AND HOW WE USE THEM

6.1 Cookies are small data files that are necessary for proper site functionality and are therefore placed on your computer as most websites. These are text files that web pages store on your computer or mobile devices when you start using them.

6.2 The pages thus remember the actions and settings you have made on them for a certain time – for example, signing in to your account. Therefore, you do not need to re-enter these data each time you visit a site and transition between different sections of the site.

6.3 We also use cookies to collect statistics and customize ads to further improve our site and improve the services we offer. We therefore share our advertising and analysis partners with Google specifically about how we use our site. You can read about how Google treats cookies at https://www.google.com/policies/technologies/cookies/.

6.4 In the event of disagreement with the use of cookies and data obtained through our Internet sites using cookies for the purposes listed above, you may:

(a) Disable the use of cookies by setting up your Internet browser or other computer program (set your browser to anonymous mode); or
(b) You can also withdraw your consent, free of charge, either by sending an email to: privacy@actando.com, or by letter to 17 rue du Cendrier Geneva CH1201.

7. WHAT ARE YOUR RIGHTS

7.1 In connection with the processing of your personal data, you have the following rights in particular:

(a) the right to clear, transparent and understandable information about how we use your personal information and what your rights are;
(b) the right of access to personal data and the provision of any further information relating to its processing by the Company;
(c) the right to correct inaccurate and incomplete personal data;
(d) the right to delete your personal information, especially if (i) you no longer need it for further processing; (ii) You have withdrawn your consent to their processing; (iii) you have reason to object to their processing; (iv) have been processed unlawfully; or (v) must be erased according to legislation;
(e) the right to restrict the processing of your personal data if (i) you contest the accuracy of personal data for as long as we do not verify its accuracy; (ii) processing is unlawful; (iii) we do not need it any more, but you need the data for the purposes of your claims; or (iv) object to their processing until we verify that our legitimate reasons outweigh your interests;
(f) the right to object to the processing of your personal data if we process it for (i) direct marketing purposes or (ii) for the purposes of our legitimate interests;
(g) the right to acquire and transfer personal data to another service provider;
(h) the right to lodge a complaint with the institution responsible for the protection of personal data in your country.

7.2 If you wish to claim any of the above rights, please contact us using the contact details below.

8. HOW WE PROTECT YOUR PERSONAL INFORMATION

8.1 To ensure the security and confidentiality of your personal data, which is extremely important to us, we use technical and organizational measures, in particular to protect against unauthorized access to and exploitation of data, to ensure the security of our IT systems and to recover data in the event of an incident. Where appropriate, we use encryption to protect your data. We regularly evaluate and update all measures.

8.2 Personal data processing also takes place manually in electronic information systems subject to physical, technical and procedural control. In order to protect the data, we have set up a security mechanism including technical, organizational and personnel measures, and we also require the same level of protection from our processors.

9. YOU NEED FURTHER INFORMATION OR WANT TO APPLY YOUR RIGHTS

9.1 In addition to Privacy Policy webpage https://www.actando.com/privacy-policy/, the full version of the Privacy Policy and Personal Data Protection is available at the seat of the Company. You can request a written copy as described below.

9.2 If you have any queries regarding the processing of your personal data, you need any other related assistance or you wish to exercise your rights, please contact the person responsible for the area of personal data protection by telephone (at working time) by phone.: +41 22 775 33 00, by e-mail to privacy@actando.com or in writing at the above address of the Company.

This Privacy Policy enters into force on May 23, 2018