This data protection declaration clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the websites, functions and contents associated with it, as well as external online presences, such as our social media profiles (hereinafter referred to collectively as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Responsible
DREHM Pharma GmbH
Grünbergstraße 15/3/3
1120 Vienna
Austria
E-mail address: contact@drehm.at
Managing Director: Dr. Stefan Zohmann
Contact Data Protection Coordinator: privacy@drehm.at
Types of data processed:
– Inventory data (e. g. , names, addresses).
– Contact details (e. g. , e-mail, telephone numbers).
– Content data (e. g. , text input, photographs, videos).
– Usage data (e. g. , visited websites, interest in content, access times).
– Meta/communication data (e. g. , device information, IP addresses).
Categories of persons concerned
Visitors and users of the online offer (hereinafter we collectively refer to the data subject as “Users”).
Purpose of processing
– Provision of the online offer, its functions and content
– Responding to contact requests and communicating with users
– Security measures
– Reach measurement/marketing
Terms used
“Personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is a natural person who can be identified, directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier (e. g. a cookie) or one or more specific characteristics, the expression of the physical, physiological, genetic, psychological, economic, cultural or social the nature of that natural person.
“Processing” means any operation or series of operations involving personal data carried out with or without the aid of automated means. The term is wide-ranging and encompasses practically any handling of data.
“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures ensuring that the personal data are not attributed to an identified or identifiable natural person.
“Profiling” means any type of automated processing of personal data consisting in the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behaviour, whereabouts or relocations.
“Controller” means the natural or legal person, public authority, body or other body which alone or jointly with others decides on the purposes and means of the processing of personal data.
“Processor” means a natural or legal person, public authority, body or other body which processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you of the legal bases of our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consents is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for the processing for the performance of our services and the implementation of contractual measures as well as for answering queries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing to fulfil our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to safeguard our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that the vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR as the legal basis.e.
Security measures
In accordance with Art. 32 GDPR, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons.
These measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to, as well as access to, input, transfer, ensuring availability and segregation of data. In addition, we have established procedures to ensure the exercise of data subject rights, deletion of data and response to data threats. Furthermore, we take into account the protection of personal data already during the development and selection of hardware, software and processes, in accordance with the principle of data protection by technical design and by data protection-friendly default settings (Art. 25 GDPR).
Cooperation with processors and third parties
Insofar as we disclose data to other persons and companies (processors or third parties) in the course of our processing, transfer it to them or otherwise grant them access to the data, this is only done on the basis of a legal permission (e. g. if the transfer of data to third parties, such as payment service providers, is required in accordance with Art. 6 para. 1 lit. b GDPR for the performance of a contract), you have consented, a legal obligation so provides or on the basis of our legitimate interests (e. g. for the deployment of agents, Webhosters, etc. ).
If we commission third parties to process data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i. e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using third party services or disclosing or transmitting data to third parties, this will only happen if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 et seq. of the GDPR are met. This means that the processing takes place, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection equivalent to the EU (e. g. for the USA by the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
Rights of data subjects
You have the right to request confirmation as to whether data in question is being processed and to obtain information about these data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
You have accordingly. Art. 16 GDPR the right to request the completion of data concerning you or the correction of incorrect data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that the data concerned be deleted immediately, or alternatively to demand a restriction of the processing of the data in accordance with Art. 18 GDPR.
You have the right to request that the data concerning you that you have provided to us be received in accordance with Art. 20 GDPR and to request its transmission to other controllers.
They also have acc. Art. 77 GDPR the right to lodge a complaint with the competent supervisory authority.
Right of withdrawal
You have the right to revoke your consent pursuant to Art. Art. 7 para. 3 GDPR to revoke with effect for the future
Right to object
You may object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may be made in particular against processing for direct marketing purposes.
Cookies and right of objection for direct advertising
“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his/her visit within an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the content of a shopping basket in an online shop or a login status can be stored. “Permanent” or “persistent” cookies are referred to as cookies that remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. Likewise, such a cookie may store the interests of users, which are used for reach measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the controller who operates the online offer (otherwise, if they are only the controller’s cookies, they are referred to as “first-party cookies”).
We may use temporary and permanent cookies and clarify this in the context of our privacy policy.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies may lead to functional limitations of this online offer.
A general objection to the use of cookies used for online marketing purposes can be declared for many of the services, especially in the case of tracking, via the US site http://www. aboutads. info/choices/ or the EU site http://www. youronlinechoices. com/. Furthermore, the storage of cookies can be achieved by turning them off in the settings of the browser. Please note that you may not be able to use all functions of this online offer.
Deletation of data
The data processed by us are deleted or restricted in their processing in accordance with Art. 17 and 18 GDPR. Unless explicitly stated in this data protection declaration, the data stored with us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with statutory retention obligations. Unless the data is deleted because it is necessary for other and legally permissible purposes, its processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax reasons.
According to legal requirements in Germany, storage takes place in particular for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 and 4 para. 4 HGB (books, records, management reports, accounting documents, commercial books, documents relevant for taxation, etc. ) and 6 years according to § 257 para. 1 points 2 and 3, para. 4 HGB (commercial letters).
According to legal requirements in Austria, storage takes place in particular for 7 years in accordance with § 132 para. 1 BAO (accounting documents, receipts/invoices, accounts, receipts, business documents, statement of revenue and expenditure, etc. ), for 22 years in respect of land and for 10 years in respect of documents relating to electronically supplied services, telecommunications, broadcasting and television services provided to non-entrepreneurs in EU Member States using the Mini-One-Stop Shop (MOSS).
Agency services
We process the data of our clients within the scope of our contractual services which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services and training services.
We process inventory data (e. g. , customer master data, such as names or addresses), contact data (e. g. , e-mail, telephone numbers), content data (e. g. , text input, photographs, videos), contract data (e. g. , subject of the contract, duration), payment data (e. g. , bank details, payment history), usage and metadata (e. g. , in the context of the evaluation and measurement of the success of marketing measures). In principle, we do not process special categories of personal data unless these are components of an commissioned processing. The data subjects include our customers, interested parties and their customers, users, website visitors or employees as well as third parties. The purpose of the processing is to provide contractual services, billing and our customer service. The legal basis for the processing is Art. 6 para. 1 lit. b GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). We process data that is necessary for the justification and performance of the contractual services and point out the necessity of their disclosure. Disclosure to external parties will only take place if it is necessary in the context of an assignment. When processing the data provided to us in the context of an order, we act in accordance with the instructions of the client and the legal requirements of order processing pursuant to Art. Art. 28 GDPR and do not process the data for purposes other than those specified in the order.
We delete the data after expiry of statutory warranty and similar obligations. the necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry (6 J, pursuant to § 257 para. 1 HGB, 10 J, pursuant to § 147 para. 1 AO). In the case of data disclosed to us by the client in the context of an order, we delete the data according to the specifications of the order, in principle after the end of the order.
Preventive health services
We process the data of our patients and prospective customers and other clients or contractual partners (collectively referred to as “patients”) in accordance with Art. 6 para. 1 lit. b) GDPR in order to provide them with our contractual or pre-contractual services. The data processed here, the type, scope and purpose and the necessity of their processing, are determined according to the underlying contractual relationship. In principle, the processed data includes patient data (e. g. , name, address, etc. ), as well as contact data (e. g. , e-mail address, telephone, etc. ), contract data (e. g. , services used, products purchased, costs, names of contact persons) and payment data (e. g. , bank details, payment history, etc. ).
Within the scope of our services, we may also use special categories of data acc. Art. 9 para. 1 GDPR, in particular data on the health of patients, possibly in relation to their sexual life or sexual orientation. For this purpose, we bring, if necessary, acc. Art. 6 para. 1 lit. a. , Art. 7, Art. 9 para. 2 lit. a. GDPR and otherwise process the special categories of data for health care purposes on the basis of Art. 9 para. 2 lit. h. GDPR, § 22 para. 1 No. 1 b. BDSG.
Insofar as required for the performance of a contract or required by law, we disclose or transfer patient data in the context of communication with medical professionals, third parties necessarily or typically involved in the performance of the contract, such as laboratories, billing offices or similar service providers, insofar as this is necessary for the provision of our services pursuant to Art. Art. 6 para. 1 lit b. DSGVO serves, legally acc. Art. 6 para. 1 lit c. GDPR, our interests or those of patients in efficient and cost-effective healthcare as a legitimate interest pursuant to Art. Art. 6 para. 1 lit f. GDPR serves or acc. Art. 6 para. 1 lit d. GDPR is necessary. to protect the vital interests of the patient or another natural person or in the context of a consent pursuant to Art. Art. 6 para. 1 lit. a. , Art. 7 GDPR.
The deletion of the data takes place when the data is no longer required to fulfil contractual or legal care obligations and to deal with any warranty and similar obligations, whereby the necessity of the data storage is reviewed every three years; otherwise, the legal storage obligations apply.
Administration, financial accounting, office organisation, contact management
We process data in the context of administrative tasks as well as the organisation of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the context of the provision of our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing is administration, financial accounting, office organization, archiving of data, i. e. tasks that serve the maintenance of our business activities, the performance of our tasks and the provision of our services. The deletion of data for contractual services and contractual communication corresponds to the data specified in these processing activities.
We disclose or transmit data to the financial administration, consultants, such as tax consultants or auditors as well as other fee agencies and payment service providers.
Furthermore, on the basis of our business interests, we store information about suppliers, organizers and other business partners, e. g. for the purpose of establishing contact at a later date. In principle, we store these mainly company-related data permanently.
Akismet Anti-Spam Check
Our online offer uses the service “Akismet”, which is provided by Automattic Inc. , 60 29th Street #343, San Francisco, CA 94110, USA, is offered. The use is based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f) GDPR. With the help of this service, comments from real people are differentiated from spam comments. For this purpose, all comments are sent to a server in the USA, where they are analysed and stored for four days for comparison purposes. If a comment has been classified as spam, the data will be stored beyond this time. These data include the entered name, the email address, the IP address, the comment content, the referrer, information about the browser used and the computer system and the time of the entry.
Further information on the collection and use of data by Akismet can be found in Automattic’s privacy policy: https://automattic. com/privacy/.
Users are welcome to use pseudonyms, or refrain from entering their name or email address. You can completely prevent the transfer of data by not using our commenting system. That would be a pity, but unfortunately we do not see alternatives that work just as effectively.
Retrieval of profile pictures at Gravatar
We use the Gravatar service of Automattic Inc. within our online offer and especially in the blog. , 60 29th Street #343, San Francisco, CA 94110, USA, a.
Gravatar is a service where users can log in and save profile pictures and their e-mail addresses. If users leave posts or comments on other online sites (especially in blogs) with the respective email address, their profile pictures can be displayed next to the posts or comments. For this purpose, the e-mail address provided by the users is transmitted in encrypted form to Gravatar in order to check whether a profile is stored for it. This is the sole purpose of transmitting the e-mail address and it is not used for any other purpose but deleted afterwards.
The use of Gravatar is based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f) GDPR, because with the help of Gravatar we offer the contributors and commenters the opportunity to personalize their contributions with a profile picture.
By displaying the images, Gravatar learns the IP address of the users, as this is necessary for communication between a browser and an online service. Further information on the collection and use of data by Gravatar can be found in Automattic’s privacy policy: https://automattic. com/privacy/.
If users do not want a user image associated with your Gravatar e-mail address to appear in the comments, you should use an e-mail address that is not stored in Gravatar to comment. We would also like to point out that it is also possible to use an anonymous e-mail address or not at all if users do not wish to have their own e-mail address sent to Gravatar. Users can completely prevent the transfer of data by not using our commenting system.
Contact
When contacting us (e. g. via contact form, e-mail, telephone or via social media), the user’s data for processing the contact request and its processing according to Art. Art. 6 para. 1 lit. b. (in the context of contractual/pre-contractual relationships), Art. 6 para. 1 lit. f. (other requests) GDPR processed. User data may be stored in a Customer Relationship Management System (“CRM System”) or similar enquiry organization.
We will delete the requests if they are no longer required. We review the necessity every two years; furthermore, the statutory archiving obligations apply.
Hosting and e-mail dispatch
The hosting services we use are intended to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mail dispatch, security services and technical maintenance services that we use for the purpose of operating this online offer.
In doing so, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in the efficient and secure provision of this online offer pursuant to Art. Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of contract processing).
Collection of access data and log files
We, or our hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR data about each access to the server on which this service is located (so-called server log files). Access data includes the name of the accessed website, file, date and time of access, amount of data transmitted, message about successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Logfile information is stored for a maximum of 7 days for security reasons (e. g. to investigate abusive or fraudulent acts) and then deleted. Data whose further storage is necessary for evidence purposes are excluded from deletion until the event in question has been finally clarified.
Google Analytics
We use Google Analytics, a web analysis service provided by Google LLC (“Google”), based on our legitimate interests (i. e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f GDPR). Google uses cookies. The information generated by the cookie about the use of the online offer by users is usually transmitted to a Google server in the USA and stored there.
Google is certified under the Privacy Shield Agreement and thus offers a guarantee that it complies with European data protection law (https://www. privacyshield. gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the use of the internet. Pseudonymous user profiles of the users can be created from the processed data.
We only use Google Analytics with activated IP anonymization. This means that the IP address of the user is truncated by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and truncated there.
The IP address transmitted by the user’s browser is not merged with other data held by Google. Users may prevent the storage of cookies by selecting the appropriate settings in their browser software; they may also prevent the collection by Google of the data generated by the cookie and related to their use of the online offer, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: http://tools. google. com/dlpage/gaoptout?hl=de.
Further information on Google’s use of data, settings and objection options can be found in Google’s privacy policy (https://policies. google. com/technologies/ads) and in the settings for the display of advertisements by Google (https://adssettings. google. com/authenticated).
The personal data of the users is deleted or anonymized after 14 months.
Jetpack (WordPress Stats)
On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f GDPR), we use the Jetpack plugin (here the sub-function “Wordpress Stats”), which incorporates a tool for the statistical evaluation of visitor accesses and is provided by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. Jetpack uses so-called “cookies”, text files that are stored on your computer and that enable an analysis of your use of the website.
The information generated by the cookie about your use of this online offer is stored on a server in the USA. Usage profiles of the users can be created from the processed data, whereby these are only used for analysis and not for advertising purposes. For more information, please refer to Automattic’s privacy statements: https://automattic.com/privacy/ and notes on Jetpack cookies: https://jetpack.com/support/cookies/.
Online presence in social media
We maintain online presences within social networks and platforms in order to communicate with customers, prospects and users active there and to inform them about our services.
Please note that user data may be processed outside the territory of the European Union. This may result in risks for users, for example because it could make the enforcement of users’ rights more difficult. With regard to US providers certified under the Privacy Shield, we would like to point out that they are committed to complying with EU data protection standards.
Furthermore, the data of the users is usually processed for market research and advertising purposes. For example, usage profiles can be created from the user behaviour and the resulting interests of the user. The usage profiles can in turn be used, for example, to place advertisements inside and outside the platforms that are presumably in line with the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the user’s usage behaviour and interests are stored. Furthermore, data may be stored in the usage profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
The processing of users’ personal data takes place on the basis of our legitimate interests in effective information of users and communication with users according to Art. Art. 6 para. 1 lit. f. GDPR. If the users are asked for their consent to data processing by the respective providers (i. e. they declare their consent, e. g. by ticking a checkbox or confirming a button), the legal basis for the processing is Art. 6 para. 1 lit. a. , Art. 7 GDPR.
For a detailed description of the respective processing and the possibilities of objection (opt-out), please refer to the following linked information of the providers.
Also in the case of requests for information and the assertion of user rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please contact us.
– Facebook (Facebook Ireland Ltd. , 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) – Privacy Policy: https://www. facebook. com/about/privacy/, Opt-Out: https://www. facebook. com/settings?tab=ads and http://www. youronlinechoices. com, Privacy Shield: https://www. privacyshield. gov/participant?id=a2zt0000000GnywAAC&status=Active.
– Google/ YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Privacy Policy: https://policies. google. com/privacy, Opt-Out: https://adssettings. google. com/authenticated, Privacy Shield: https://www. privacyshield. gov/participant?id=a2zt000000001L5AAI&status=Active.
– Instagram (Instagram Inc. , 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy Policy/ Opt-Out: http://instagram. com/about/legal/privacy/.
– Twitter (Twitter Inc. , 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Privacy Policy: https://twitter. com/de/privacy, Opt-Out: https://twitter. com/personalization, Privacy Shield: https://www. privacyshield. gov/participant?id=a2zt0000000TORzAAO&status=Active.
– Pinterest (Pinterest Inc. , 635 High Street, Palo Alto, CA, 94301, USA) – Privacy Policy/ Opt-Out: https://about. pinterest. com/de/privacy-policy.
– LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) – Privacy Policy: https://www. linkedin. com/legal/privacy-policy , Opt-Out: https://www. linkedin. com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www. privacyshield. gov/participantid=a2zt0000000L0UZAA0&status=Active.
– XING (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) – Privacy Policy/ Opt-Out: https://privacy. xing. com/de/datenschutzerklaerung.
– Wakalet (Wakelet Limited, 76 Quay Street, Manchester, M3 4PR, United Kingdom) – Privacy Policy/ Opt-Out: https://wakelet. com/privacy. html.
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