Updated September 2018

Dr Falk Pharma UK Ltd Website Cookies and Privacy Policy

Use of Cookies

Dr Falk collects information from you by using ‘cookies’.  

Cookies gather information such as how and when pages in a website are visited and by how many people.  They are a small file of letters and numbers stored on your browser or the hard drive of your computer if you agree.

Cookies we use What the Cookies do
_gat Google Analytic tracking
_ga Google Analytic tracking
_gid Google Analytic tracking
wordpress_test_cookie

 

WordPress sets this cookie when you navigate to the login page. The cookie is used to check whether your web browser is set to allow or reject cookies.  It expires when you close the site. This is a necessary cookie for any password protected area.
wordpress_logged_in_#

 

After login, wordpress sets the wordpress_logged_in_# cookie, which indicates when you’re logged in and who you are for most interface use. It expires when you close the site.  This is a necessary cookie for any password protected area.
wordpress_sec_#

 

This cookie is used to store your authentication details. Its use is limited to the admin console area. It expires when you close the site.  This is a necessary cookie for any password protected area.

Any third party links on our site may also use cookies; you may receive these cookies by clicking on the link to the third party site.  We do not control the collection or use of information by these third parties and these third party cookies are not subject to our Privacy Notice.  You should contact these companies directly if you have any questions about their collection and/or use of information.

Why we use these Cookies

With the information we receive through this technology, we hope to improve our site.  Although cookies do not normally contain personally identifiable information, if you have provided us with information about yourself, we may be able to identify you by associating your registration information with cookies or other tracking utilities our website places on your computer’s hard drive.  Associating a cookie with your registration information allows us to offer increased personalization and functionality.  Without cookies, this functionality would not be possible.

How to disable Cookies

Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to you.  If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website and some website functionality may be lost.  The Help section of your browser will tell you how to prevent your browser from accepting cookies.  To find out more about cookies, including how to see what cookies have been set and how to manage or delete them, visit www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit  http://tools.google.com/dlpage/gaoptout.

 

This statement was last updated in May 2018

 

Privacy Notice

 Dr Falk Pharma UK Ltd (Dr Falk) respects the privacy of visitors to its website (the ‘Site’) and is committed to the protection of their personal information and to compliance with the General Data Protection Regulation (GDPR) in all activities, whether through the Site or elsewhere.

This Privacy Notice explains how we manage personal information collected from, or provided by, you through the Site or any services accessible through the Site or from any other source.

We may occasionally update this Privacy Notice.  If the changes we make are material, we will post an update.  We encourage you to periodically review the Privacy Notice and our Cookie Policy to stay informed.

Contents of this Privacy Notice:

  1. Who we are
  2. How we collect information
  3. What information we hold
  4. The legal basis we rely on
  5. Why we hold the information
  6. What we may do with the information
  7. Sharing the information
  8. How long we keep the information
  9. Protection of the information
  10. Your rights
  11. Contact us
  12. Contact the Regulator/make a complaint

 

  1. Who we are

We are Dr Falk Pharma UK Limited, a company registered in England under company number 02307698.  Our registered office is Unit K, Bourne End Business Park, Cores End Road, Bourne End, SL8 5AS.  Email:  Office@drfalkpharma.co.uk.  Phone:  01628 536600.

We are the Data Controller and a Data Processor under the terms of the GDPR for Dr Falk Pharma UK Ltd.

 

  1. How we collect information

Personal Information

You typically give this information to us via this Site and/or by correspondence or telephone and/or in face to face discussions when you request educational literature, register for a meeting, subscribe to the Newsletter or discuss medicinal products with us.

System information collected from IP addresses

An Internet Protocol (IP) address is a set of numbers that is automatically assigned to your computer whenever you log on to your internet service provider or through your organisation’s local area network (LAN) or wide area network (WAN).  Web servers automatically identify your computer by the IP address assigned to it during your session online.

We also collect data by use of Cookies (see our Cookies notice).

 

  1. What information we hold

The main category of personal data we collect is contact information of healthcare professionals.  We directly collect personally identifiable information, i.e., information from which you can be identified, such as name, address, telephone number and/or e-mail address. We may also need to ask for other specific information, for example, if you are attending a meeting we organise we may ask if you have any dietary requirements.  This is to accommodate your requirements at meetings.

When we sponsor you to attend a medical meeting, personal information may be passed to a travel agency acting on our behalf. When the meeting is abroad, they may require information from your passport so that they can arrange your travel.  The data will be processed by all parties according to the requirements of the Regulation.

We do not request any information categorised as sensitive, for example, on race, politics or religion.

In cases where you send sensitive data, for example, about your health or about an adverse drug reaction, it is anonymised before being processed.  If necessary for regulatory requirements, any identifying data are separately and securely stored, otherwise they will be deleted following anonymisation.  The anonymised data may be included in the EMA’s Eudravigilance database and will be included in our safety database, which is located in the EU and managed by a third party.

Dr Falk automatically collects (where available) information about your browser type and operating system, websites you visited before and after visiting the Site, standard server log information and IP Address (see below).  This information is aggregated to gather data such as the total number of visits to the Site, the number of visitors to each page of the Site and the domain names of our visitors’ internet service providers.

In addition, we hold data collected by Cookies.

This Site is not intended for, or designed to attract, children under the age of 18.  We do not knowingly collect personally identifiable information via this Site from visitors in that age group.

 

  1. The legal basis we rely on

To be in compliance with the GDPR we have reviewed the data we collect and the reasons and legal basis for doing so.  The GDPR defines different reasons a company may collect and process personal data. The data that Dr Falk collects will be in compliance with one of the reasons listed:

Consent

In specific situations, we can collect and process your data with your consent – e.g., when you ask us to arrange travel on your behalf.  When collecting your personal data, we will always make clear to you which data are necessary in connection with a particular service.

 Contractual obligations

In some instances, we need your personal data to comply with our contractual obligations.  For example, if you place an order with us for literature, we need your address details to deliver your order and we may need to pass your details to a courier

Legitimate interest

We collect your data to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom or interests.

 Legal obligation

With regard to special categories of personal data (sensitive data) we are required to collect and process anonymised health data for the reasons of public interest in ensuring high standards of medicinal products (Article 9.2.i of the GDPR).

 

  1. Why we hold the information

We only request and collect the information needed for each situation.

We collect your IP address, which remains in aggregate form, to understand how our visitors use the Site so that we may improve it and the services we offer.  We may also share this aggregated information with other companies within the Dr Falk Pharma group and with other third parties.

Dr Falk, or third party companies acting on behalf of Dr Falk, may collect IP addresses for the purposes of systems administration and analysing the use of the Site.  We also may use IP addresses to identify users of the Site when we feel it is necessary to enforce compliance with the Site’s terms of use or to protect our service, Site or other users.

 

  1. What we may do with the information

 We may:

Store your email in our email system.

File your hard-copy communication and/or sensitive information in a secure place.

Add information to our interactions database.

Analyse your information to create a profile of your professional interests and preferences.

We may use your information to:

Respond to your request for information.

Register you for an event and inform event managers.

Organise your travel and accommodation for events.

Issue Continuing Professional Development points following a CPD accredited event organised by us.

Publicise you if you win an award sponsored by us.

Provide you with product and other information via the Site or other routes.

Provide you with news of our services and events via the Site or other routes.

Send you the Dr Falk e-Newsletter.

Consider your application for employment or service provision.

Manage any complaint or report of adverse drug reaction.

Manage a request for medical information.

Fulfil requirements of professional bodies such as the ABPI.

Improve our level of service and the content of our Site.

We don’t use the data for automated decision making or profiling.

 

  1. Sharing the information

Dr Falk will not share, sell or rent personally identifiable information to third parties other than as stated in this Notice.  Sometimes selected third parties are used to provide Dr Falk with support services in connection with the Site and other company business processes and such parties may, from time to time, have access to your information to enable them to provide those services to Dr Falk.  An example of this would be a third party that provides IT support.

All companies providing support services are required by Dr Falk to meet the same standards of data protection as Dr Falk and are prohibited from using the information for their own purposes.  In particular, we do not allow our service providers to use personally identifiable information disclosed by us for their own marketing activities.

We may disclose personally identifiable information to any member of our group which means our holding company and its subsidiaries and/or in the following circumstances:

  • when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to you, or otherwise injuring or interfering with Dr Falk’s rights, property or operations, other users of this Site and/or their rights, or anyone else who could be harmed by such activities; and/or
  • when we believe the law requires it, or we are under a duty to disclose or share your data to comply with a legal obligation or in response to any demand by law enforcement authorities in connection with a criminal investigation, or civil or administrative authorities in connection with a pending civil case or administrative investigation; and/or
  • in connection with a substantial corporate transaction, such as the sale of a product line or division, an investment in our business, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy in which case we may disclose personal data to the prospective seller, buyer or investor; and/or
  • We may share the data with any government agency entitled to this information by law.

Personally identifiable information collected on the Site may be transferred, stored and processed in compliance with Chapter V of the Regulation, ‘Transfers of personal data to third countries or international organisations’.

Links to other websites

This Site may from time to time provide links to other websites as a service to our users.  This Privacy Notice does not apply to those websites.  If you choose to enter such a linked site you agree that Dr Falk is not responsible for the availability of such websites and does not review or endorse and shall not be liable, directly or indirectly, for (i) how these websites treat your personally identifiable information, (ii) the content of such websites, including (without limitation) any advertising, products, goods or other materials or services available from such websites and (iii) the use that others make of these websites.

Please ensure that you check the legal and privacy statement posted on each website you link to before entering any personally identifiable information.

 

  1. How long we keep the information

We retain the data we collect for as long as needed to carry out the task for which it was collected, for example, data to fulfil a request for literature will only be kept until the order is fulfilled, after which it will be securely deleted.  In some cases we may need to keep it longer, for example, if we are in an on-going dialogue with you for educational and/or marketing purposes.  In other cases, there may be legal/regulatory reasons to keep the data for much longer, for example the data to meet the needs of the ABPI Disclosure requirements.

 

  1. Protection of the information

 Dr Falk is committed to using commercially reasonable means to ensure that your personally identifiable information is protected appropriately, according to the sensitivity of the information.  Dr Falk uses a variety of security technologies and procedures to help protect your personally identifiable information from unauthorized access, use, or disclosure.  For example, we store the personally identifiable information you provide to Dr Falk on computer servers with limited access that are located in controlled facilities.

Unfortunately, the transmission of information via the internet is not completely secure.  Although we will do our best to protect personally identifiable information, we cannot guarantee the security of the personally identifiable information during transmission to the Site; any transmission is at your own risk.  While we cannot guarantee that loss, misuse or alteration to data will not occur, once we have received your information, we make commercially reasonable efforts to prevent such unfortunate occurrences.

The database and email system are held on a secure server, regularly backed up and hosted in the UK.

 

  1. Your rights

You have a choice as to whether or not you receive information from us and you can unsubscribe from communications and/or request that data processing ceases, at any time.

You have the right to ask us

  • for copies of your personal information.
  • to rectify information you think is inaccurate.
  • to complete information you think is incomplete.
  • to erase your personal information.
  • to restrict or end the processing of your information.
  • to transfer the information you gave us from one organisation to another, or give it to you.

Contact us in writing at the address below or by email.

You can also click the ‘unsubscribe’ link in any email communication that we send you.  We will then stop any further emails

We aim to deal with your request (including unsubscribing you from any programme) within ten working days of its receipt.

 

  1. Contact us

 Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to:

Dr Falk Pharma UK Ltd, Unit K, Bourne End Business Park, Cores End Road, Bourne End, SL8 5AS

Alternatively, email us at privacy@drfalkpharma.co.uk

 

  1. Contact the Regulator/make a complaint

For more information visit the ICO’s website https://ico.org.uk/

If you are at all unhappy about the handling of your data, you can send a complaint to the Information Commissioner’s Office by calling 0303 123 1113 or go online to https://ico.org.uk/make-a-complaint/  If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

 

This Notice was last updated in July 2018