Privacy Policy and Personal Data Protection - REPI

REPI and its owner and manager – ActOne, S.A., undertakes to maintain the privacy and the confidentiality of all the information provided by the User. This Privacy Policy establishes the measures adopted by REPI and its owner and manager – ActOne, S.A., regarding the Personal Data collected directly from the User (Pharmaceutical Industry Representative or Healthcare Professional) and/or through the website www.pharmarepi.com, in accordance with the General Data Protection Regulation and other applicable national and international legislation. The expression "Personal Data" refers to all the personal information provided by the User (Pharmaceutical Industry Representative or Healthcare Professional), such as name, profession, date of birth, telephone number, address or e-mail address. It may be conferred to the user the definition of Pharmaceutical Industry Representative or Healthcare Professional. Throughout this document any reference to REPI is and it will always be extended to its owner and manager – ActOne, S.A.

General Privacy Rules and Personal Data Processing

The Personal Data provided will be used by REPI in the provision of the requested service. To the User (Pharmaceutical Industry Representative or Healthcare Professional) it will only be requested the Personal Data which is strictly necessary and relevant to the provision of the service. The information will be sent by REPI to the address or to the electronic mail provided by the User (Pharmaceutical Industry Representative or Healthcare Professional).

 ActOne, S.A. respects all the legal requirements regarding to the personal data processing which is made available by all those who engage with the Company. Those personal data processing is in fully accordance with the General Data Protection Regulation (Regulation EU 2016/679 of April 27, 2016) and other legal impositions.

 The provision of personal data, by the user, on this platform, implies the knowledge and the acceptance of the conditions contained in this Privacy Policy.

Identity and contacts of the data controller

The entity responsible for the collection and processing of personal data is ActOne, S.A., since it is the person who determines the purposes and means of the processing of the personal data which are provided to him.

The contacts of ActOne, S.A. are: e-mail geral@actone.pt, or ActOne S.A., Alfrapark, Estrada de Alfragide, nº 67, Piso F, Piso 1, Sul, 2610-008 Amadora

What kind of personal data are collected

ActOne, S.A. collects and processes the personal data necessary to provide services related to the REPI platform, such as the name, professional name, professional identification number, e-mail, telephone contact, date of birth, gender, starting year of work, correspondence address, specialty, professional domicile, country or nationality and geographical information.

How to collect your personal data

The personal data are provided by the owner of the same, after their registration in the platform.

Purposes of the processing of personal data

The personal data collected are intended to the service provision requested by the REPI platform which is to create a personal account on a multichannel communication platform with representative professionals of the pharmaceutical industry. REPI may also send information about new products and/or services related with communication and marketing; regular updates that REPI considers of interest to the User (Pharmaceutical Industry Representative or Healthcare Professional).

How long will the personal data be stored

The data will be kept for as long as the data subject are professionally active and as long as the data subject does not proceed with the cancellation of the user account.

How to access, rectify or oppose the processing of your personal data

In accordance with Regulation (EU) 2016/679 of 27 April 2016, the data subject has the right to access, update, rectify or request the erasure of their personal data.

To this end, the User (Pharmaceutical Industry Representative or Healthcare Professional) must contact ActOne, S.A. in writing through the e-mail privacy@actone.pt or to the address indicated in the contacts provided in this Privacy Policy. Regarding the Pharmaceutical Industry Representative, this process will be obviously focused on the Pharmaceutical Company which is the employer of the Pharmaceutical Industry Representative in question.

How to withdraw my consent

The data subject must contact ActOne, S.A. in writing through the email privacy@actone.pt or to the address indicated in the contacts provided in this Privacy Policy.

Claims

Under the terms of the General Data Protection Regulation, the data subject has the right to submit any complaint to the National Data Protection Commission, without prejudice to any other administrative or extrajudicial remedy.

Security, Privacy and Confidentiality

REPI has adopted, regarding the personal data, the adequate security measures for the protection of personal data and has installed all the means and technical measures at its disposal to prevent loss, misuse, alteration, unauthorized access and theft of personal data provided by User (Pharmaceutical Industry Representative or Healthcare Professional). However, any User (Pharmaceutical Industry Representative or Healthcare Professional) should be aware that the data transmissions on the Internet only benefit from a relative technical reliability and there is a risk that unauthorized third parties may access the personal data of the registered Users (Pharmaceutical Industry Representative or Healthcare Professional).

Although REPI has taken the necessary measures to ensure the safety of its Users (Pharmaceutical Industry Representative or Healthcare Professional), it is the responsibility of each User (Pharmaceutical Industry Representative or Healthcare Professional) to adopt measures to maintain the confidentiality of their access password. It is also the duty of the User (Pharmaceutical Industry Representative or Healthcare Professional) to ensure that all the information made available by the REPI system is correct, true and latest. Without prejudice of the verification made by REPI, it is the User's responsibility (Pharmaceutical Industry Representative or Healthcare Professional) all the information that the same uploads and provides to the system.

Any user (Pharmaceutical Industry Representative or Healthcare Professional) can freely navigate through the platform www.pharmarepi.com, not being collected any personal data. Personal data collected by REPI are provided exclusively and voluntarily by the users (Pharmaceutical Industry Representative or Healthcare Professional) of this website.

To protect and to ensure the integrity of our users’ information (Pharmaceutical Industry Representative or Healthcare Professional), REPI uses industry-leading security technology for production, communication and storage. All personal and professional data received on our systems is automatically processed and stored in a secure and credible way due to the fact that it had being created all the possible technical conditions to avoid any misuse.

All communications (text, sound and video) made with REPI or performed between the users (Pharmaceutical Industry Representative or Healthcare Professional) are completely encrypted and cannot be accessed by third parties due to the HTTPS security system. When the User (Pharmaceutical Industry Representative or Healthcare Professional) access REPI or the reserved area, the user is accessing a secure and confidential domain where the communications are performed under the HTTPS protocol which ensures that the information exchanged between the REPI server and the user’s computers (PCs, Smartphones or Tablets) is encrypted and it is not deciphered by possible attackers. All the website security and the processes have been audited by an external certified entity (Digicert).

REPI in its video call functionality does not have any type of software or system that would record the interaction of the two parties because it is not the REPI's policy the recording of their video calls users (Pharmaceutical Industry Representative or Healthcare Professional).

Collection of anonymous data through the website www.pharmarepi.com

In addition to the collection of data by the above means, REPI uses technology that allows the collection of information about the Users (Pharmaceutical Industry Representative or Healthcare Professional) from the website www.pharmarepi.com. For example, the website server automatically collects the pages visited, the User's IP address (Pharmaceutical Industry Representative or Healthcare Professional) and the web browser that it is used. This technology does not allow the personal identification of the User (Pharmaceutical Industry Representative or Healthcare Professional), nor it is its purpose, serving only for statistical purposes and for the improvement of our services.

Our website contains links to other websites. Technology may also be used to monitor how often these links are used and which websites are the most visited. Again, this technology does not allow the personal identification of the User (Pharmaceutical Industry Representative or Healthcare Professional) – serving only for statistical purposes and for the improvement of our services.

Cookies Policy

In order to collect the information referred to in the previous paragraph, it may be used temporary cookies which will remain in the cookies file of the User's web browser (Pharmaceutical Industry Representative or Healthcare Professional) until it is closed. Cookies by themselves do not serve to identify the User (Pharmaceutical Industry Representative or Healthcare Professional). The cookie is a small piece of information sent to the User's server (Healthcare Professional or Representative of the Pharmaceutical Industry) and stored on the user’s computer’s hard drive, causing no damage to it. The User (Pharmaceutical Industry Representative or Healthcare Professional) may program the web browser in order to be notified whenever receives a cookie, so that he can choose to accept or reject it.

We also use the User's IP address (Pharmaceutical Industry Representative or Healthcare Professional) to help to diagnose problems with the User’s server and to administrate our website conveniently, keeping in mind the continued improvement of our services. The IP address is a numeric code that identifies a computer on the network, or in this case, in the Internet. The User's IP address (Pharmaceutical Industry Representative or Healthcare Professional) is also used to collect geographic information. We may also conduct IP surveys to determine from which domain the User (Pharmaceutical Industry Representative or Healthcare Professional) set out to better gauge the User's geographical data (Pharmaceutical Industry Representative or Healthcare Professional).

Disclosure of Personal Data

REPI does not disclose, sell or distribute the Personal Data collected to third parties that have no relation to the provision of the service, unless otherwise stated and in the following situations: To provide to the User (Pharmaceutical Industry Representative or Healthcare Professional) the requested information or products, the Personal Data provided may be transferred or shared with other companies belonging to the REPI representative group or with third parties acting on behalf of the REPI for further processing, in accordance with the purposes of which the data was collected, or only in the cases authorized by the User (Pharmaceutical Industry Representative or Healthcare Professional). For example, sometimes a third party may have access to the Personal Data to support information technology or to manage correspondence on behalf of REPI.

In cases which the User (Pharmaceutical Industry Representative or Healthcare Professional) has consented, the User’s Personal Data may be shared with other companies belonging to the same REPI representative group or the same data can be disclosed to other companies that may contact the User about their products or services that can be of the User’s interest.

REPI may share, transfer or disclose information from its database and server logs to comply with any governmental, judicial, administrative order, or to interact with anti-fraud databases, or to protect the user's vital interests (Pharmaceutical Industry Representative or Healthcare Professional), or to protect the security or integrity of our databases or the website, or to take action against legal liability, or in the case of a sale, merger, reorganization, dissolution or other event related to REPIREPI will inform the User (Pharmaceutical Industry Representative or Healthcare Professional) in case of transfer or disclosure of the data, in accordance with the legal requirements.

When appropriate, before disclosing Personal Data to a third party, REPI will contractually establish with that third party the obligation to take all the necessary measures to protect the received data and to comply with all the applicable legislation.

Links to other sites

The website www.pharmarepi.com may contain links to websites which are not operated by REPI. These links are made available only for reference and convenience of the User (Pharmaceutical Industry Representative or Healthcare Professional) and it does not imply any endorsement or acceptance of the activities of those third parties or any association with those operators. REPI does not control these websites and is not responsible for its data and privacy policy. In this case, we recommend that the User (Pharmaceutical Industry Representative or Healthcare Professional) looks for information about the Privacy Policy before using any site or providing any Personal Data.

Transfer of data to and from abroad

If the User (Pharmaceutical Industry Representative or Healthcare Professional) is in a different country from the one where the REPI's servers are located, the communications may result in a trans-border information transfer. In such cases, ActOne, S.A., as the entity responsible for the processing, ensures that any personal data transfer, on the terms set forth, it will only be performed if the conditions established by the General Regulation Data Protection are respected.

By visiting our website and communicating with REPI by electronic means, the User (Pharmaceutical Industry Representative or Healthcare Professional) authorizes the processing and transfer of the Personal Data as set forth in this Privacy Policy.

Applicable Law

This Privacy Policy is an integral part of the Terms and Uses of the site www.pharmarepi.com. In case of controversy or claim of any nature related to this website, it will be applicable the Portuguese law, regardless of any laws conflict applicable. All the legal actions or proceedings arising from or related to this Privacy Policy, its validity, application, compliance or non-compliance, or the subject matter of this Privacy Policy, shall be submitted to the Portuguese courts, and the User (Pharmaceutical Industry Representative or Healthcare Professional) hereby consents to and irrevocably submits to the jurisdiction of these courts in the cases indicated. Notwithstanding the foregoing, REPI reserves the right to bring a competent action in any jurisdiction in which the breach of this Privacy Policy is found.

Notification in case of changes to the Privacy Policy

We are constantly improving our products and services and adding new features to the website www.pharmarepi.com, as well as to the existing services and products. Due to these constant changes and improvements, like the modifications in the applicable legal regime and in the evolution of the technology itself, our practices regarding data processing may also change. If it occurs any amendment to this Privacy Policy, REPI will promptly notify the User (Pharmaceutical Industry Representative or Healthcare Professional), as well as the responsible local authority, in cases required by law. 

When you choose to purchase the products or services from www.pharmarepi.com or receive additional information from REPI, you may be asked to provide the following information: name, address, e-mail address, mobile phone, data proving the profession and/or educational qualifications. You will also be asked for geographical information so that REPI can provide you with a more personalized service. The information provided will be archived in the REPI databases, either manually or by electronic means. REPI may complement the information provided by the User (Pharmaceutical Industry Representative or Healthcare Professional) with the information provided by third parties, such as, for example, if an incorrect postal code is provided, REPI may use third parties to correct this information.

Comments

REPI appreciates that for any comments about this Privacy Policy or any other question, the User (Pharmaceutical Industry Representative or Healthcare Professional) directly contact REPI through the electronic mail address geral@repi.pt or in writing to the headquarters address and/or ActOne, the owner and manager of REPI, through the contacts indicated below: (WHICH ARE ALREADY THERE ON THE WEBSITE)

For more information, see ActOne's Privacy Policy.

(http://actone.pt/pt_politica_de_privacidade.html)

Last updated: May 14, 2018