Privacy Notice
Information on Processing of Personal Data by Swixx
1. In order to meet the relevant requirements of the Regulation 2016/679 (EU) 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 (General Data Protection Regulation, hereinafter referred to as “GDPR”) and other applicable data protection laws, including Act CXII of 2011 on the right to information self-determination and freedom of information, we would like to inform you that Swixx Biopharma d.o.o., with its registered office at 1231 Ljubljana-Črnuče, Pot k sejmišču 35., Slovenia (hereinafter referred to as “SWIXX”), shall process your personal data and act as a data controller within the meaning of the GDPR.
2. SWIXX will process your personal data on the following legal basis and for the following purposes:
a. with your consent we will include your details into our database that will allow us to visit you or contact you via electronic means in order to provide you with professional information, to invite you to and/or seek your involvement in promotional, scientific and educational activities and meetings or events that might be of interest to you, to respond to your request for information you have requested or otherwise respond to your enquiry;
b. to fulfil our legal obligations and obligations of the companies we represent or partner with (“Partners”) – to report the safety or quality issues relating to products we commercialize, including all activities required for keeping a register of reports of isolated cases of adverse reactions to medicinal products (pharmacovigilance);
c. to take steps at your request prior to entering into a contract if we agree on your potential involvement in SWIXX future activities and generally to perform a contract we have entered into;
d. with your consent, we will disclose the payments or other transfer of value provided to you based on our contract; and
e. to pursue our legitimate interest – we will process personal data for administrative purposes such as management, research, analytics, organizational reporting and activities of similar nature.
3. SWIXX may transfer your personal data in the course of fulfilling legal purposes of the processing to the following categories of recipients:
a. for all the purposes indicated under point 2 above the data can be transferred to our affiliated companies for the purposes of our group management, suppliers of IT, mail and courier services, external advisors (e.g., lawyers, accountants, auditors), marketing authorization holders of medicinal products we present to you and other service providers;
b. for all the purposes indicated under point 2 above we may share the data with government authorities and/or law enforcement bodies if required by law or if required to enforce our rights and legitimate interests (including legitimate interests of third parties) in compliance with applicable laws;
c. for the purposes indicated under point 2b above the data may be transferred to marketing authorization holders or their appointed representatives, domestic and European pharmacovigilance authorities and our affiliated companies; and
d. for the purposes indicated under point 2d above the data can be transferred to an independent organization maintaining the list of payments/transfers of value.
4. We could get your information during our professional interactions when:
• we register your interest in and potential participation in events organised or sponsored by SWIXX or our Partners, such as conferences, symposia, seminars and similar occasions;
• you contact us to request medical information, or you wish to report potential safety or quality concerns; or
• you provide consultancy or other professional services to us.
5. We process only data you have provided, including:
• Full name and surname; academic title; HCP´s details (incl. medical title, specialization, place of employment, phone numbers, e-mail address; addresses of the healthcare institution (incl. street, country, city, postal code), other information as necessary and appropriate, including for example, travel related documentation.
6. It is our commitment that your data is accurate, adequate, up to date, relevant and kept safe and that it is used for the agreed purpose.
7. We will keep your personal data only for period necessary for fulfilment of legal purposes of processing described under point 2 above. Data processed with your consent or as a part of precontractual activities will be retained for a period of 24 months following our last communication with you. Data processed as part of pharmacovigilance duties will be retained for period designated in the applicable law as amended from time to time.
8. In relation to the personal data we process, you have the following rights:
• right of access to your personal data, i.e. right to obtain confirmation from us as to whether or not your personal data are being processed, and, where that is the case, to access such personal data and obtain information as to scope, method, purpose and duration of such processing;
• right to rectification, i.e. to request correction of inaccurate or amendment of incomplete personal data related to you;
• right to deletion of personal data (right to be forgotten), i.e. the right, under the conditions set out in GDPR, to have your personal data deleted for example in cases when such data are no longer necessary in relation to the purposes for which they were collected, consent to their processing has been withdrawn, objection to their further processing has been made or they were processed unlawfully;
• right to object to our further processing of your personal data for example in cases where the processing is based on legitimate interest;
• right of restriction of processing of your personal data for example when the accuracy of personal data is contested or the personal data were unlawfully processed;
• right to personal data portability, i.e. right to receive the your personal data in a structured, commonly used and machine-readable format and to transmit those data to another controller, under the conditions set out in GDPR and to the extent of our technical capabilities; and
• right to withdraw of your consent for personal data processing where your personal data are processed based on your consent without affecting lawfulness of processing performed before such withdrawal.
Please note that some of your rights can be limited or subject to further requirements and limitations as described under GDPR. In order to exercise such rights, or in case of any questions regarding processing of your personal data please contact SWIXX on the following details Swixx Biopharma d.o.o., with its registered office at 1231 Ljubljana-Črnuče, Pot k sejmišču 35., Slovenia, e-mail: data@swixxbiopharma.com or if you are not satisfied with our response, you are entitled to file a complaint with Hungarian National Authority for Data Protection and Freedom of Information at H-1055 Budapest, Falk Miksa utca 9-11, Hungary.
9. SWIXX may transfer your personal data to Switzerland where its parent company is established or to Serbia, where it has its affiliated company and servers. Switzerland maintains adequate level of protection of your personal data pursuant to an Adequacy Decision of European Commission and therefore no additional safeguards are necessary to protect your personal data. Serbia does not maintain adequate level of protection of your personal data and there is no Adequacy Decision of European Commission and therefore we implemented additional safeguards to ensure that your personal data are adequately protected, in particular we entered into Standard Contractual Clauses with our parent company Swixx Biopharma AG as well as with our Serbian affiliate Amicus SRB d.o.o. You may find the standard wording of these Clauses at the webpage of European Commission at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en or you may write to us using the contact details in point 8 above for the copy of the signed Clauses.
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We use two types of Cookies: (1) Necessary Cookies required for technical reasons, without which the website would not work perfectly, and (2) Optional Cookies: Marketing and Targeting:
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You may revoke your consent to the use of Optional Cookies at any time by changing your settings in the table above. Of course, you may use our website without the use of Cookies (including Cookies used for technical reasons). You may deactivate or restrict the use of cookies in your browser at any time, which may adversely affect the usability or user-friendliness of the site.
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The most popular browsers’ cookie settings may be found below:
Google Chrome – https://support.google.com/accounts/answer/61416
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Microsoft Internet Explorer – https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11
Microsoft Edge – https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy
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Last updated: 2023.02.27.