Privacy Policy

Almirall is committed to the safeguard of the privacy of its stakeholders and the compliance of the data protection principles and applicable laws.

This Privacy Policy together with our Terms of Use and our Cookies Policy sets out the basis on which any personal data we collect from you when you navigate in Almirall.dermatologycongress.com (the “Site”) will be collected and processed by us.

By visiting our Site you are agreeing to the practices described in this policy. By using the Site, you agree to the terms and conditions of this Privacy Policy.

For more information about this document or how we process your personal data, you can contact our Global Data Protection Officer at the e-mail address dpo.global@almirall.com

1. Basic Information

   Who is the controller of the data you provide?	The legal entity which is collecting and processing your data as data controller are the companies of the Almirall group, being the parent company Almirall S.A.. You can find more information about us at www.almirall.com
   For what purposes do we need your personal data?	We may use your personal data to make you available the use of the Site.
   Which is our lawfulness to process your personal data?	Depending on the specific purpose, our lawfulness lies on the compliance with a legal obligation, your consent or our legitimate interest.
   For how long will we keep your personal data?	Your personal data will be stored and processed until the period of time in which Almirall is obliged to comply with any legal obligation that may arise in connection with this Site
   Are we going to share your personal data?	Data will not be shared with third parties other than our service providers who help us to provide you with the use of the Site.
   Which are your rights as data subject and how you can exercise them?	The exercise of the rights that are foreseen under the General Data Protection Regulations and other applicable local legislation would be applicable in accordance with the technical and organizational particularities of the corresponding data processing performed.
   Additional information	For further information regarding Privacy and Data Protection, please click here (insert hyperlink to additional info).

2. Additional information
   1. Who is the controller of the data we collect?

      For the purpose of the General Data Protection Regulation and any local applicable laws, the data controller of the data you provide through this Site are the companies belonging to the Almirall group (visit www.almirall.com), whose parent company is Almirall S.A., a Spanish company with registered office at Ronda del General Mitre, 151, 08022- Barcelona (Spain), with VAT number A-58869389, registered at the Companies Registry of Barcelona at Volume 21795, Sheet 32, Page no. B-28.089 and with the Ministry for Health and Consumer Affairs Registration Number – 1889E.

      You can contact Us at the telephone number (+34) 93 291 30 00.

      Please note that “data controller” means the legal entity that decides the purposes and means of processing your personal data.

   2. Which kind of personal data do we process?

      a) Information you give us

      You may give us information through different forms available in the Site for many different purposes, such as to ask for medical information on our products or to give us feedback on any particular matter.

      In each case, we try to limit the necessary information we need for the purposes to process your request in each case.

      The information you give us may include your name, surname, e-mail address, country, and phone number, among other information you may freely decide to provide to us.

      b) Information we collect about you.

      As you navigate around the Site, certain information can be passively collected (that is, gathered without your actively providing the information), using various technologies. We and our third-party service providers passively collect and use information in the following ways.

      Using cookies: Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, and language preferences. We and our service providers use the information for security purposes, to facilitate navigation and to display information more effectively. We also use cookies to recognize your computer or device, which makes your use of the Site easier and makes the Site display properly on your device. In addition, we use cookies to gather statistical information about Site usage in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it. Some of our cookies are managed for us by third parties. You can refuse to accept these cookies by following your browser’s instructions; however, if you do not accept them, you may experience some inconvenience in your use of the Site. To learn more about cookies, please take a look to our Cookies Policy

      Through your browser: The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are: browser type and browser version, operating system used, deferrer URL, host name of the accessing computer, time of the server request and IP address.

      Except where expressly stated, the provision of your personal data is voluntary. However, missing or incorrect mandatory personal data may make it impossible for Almirall to provide the information you have requested.

   3. For what purposes do we need your personal data?

      Your personal data will be used to provide you with the contents to which you may have access through the Site. Among others, we may process your data for the following purposes:

      a) Drug safety: At Almirall, our commitment to the safety of our medicines, cosmetics and healthcare products starts from the Research and Development (R&D) department and is maintained throughout the life of the product. Therefore, we will use the personal data you provide us through the «Report a side effect» form to identify, quantify, assess and prevent potential risks arising of the use of our medicines, as well as follow-up of the specific case, if necessary, all in compliance with our legal obligations with the Competent Authorities in the field of pharmacovigilance, materiovigilance and cosmetovigilance. Please check our specific Global Drug Safety Privacy Policy for more details.

      b) Medical information: As part of our obligation as a pharmaceutical company, we also collect your personal data for the purposes of responding to your queries related to our products and medicines.

      c) Solve your queries or receive your feedback in relation to other matters.

      d) As the case may be, you may subscribe to email alerts from us.

      Part of the data is collected also in order to ensure error-free provision of the Site and improve the contents offered through the Site and the functionalities and also to have analytics in aggregate about the traffic of our Site.

      Your personal data will not be used for any other different purposes.

   4. For how long will we keep your personal data?

      The personal data you provide to us will be stored and processed until the period of time in which Almirall is obliged to comply with any legal obligation that may arise in connection with the Site.

   5. Which is our lawfulness to process your personal data?

      The processing of your personal data for the purposes indicated above lies on.

      a) Drug safety: compliance with a legal obligation

      b) Medical Information: compliance with a regulatory obligation to which Almirall is subject.

      c) Other queries: We have your consent when submitting your query or your comments.

      d) E-mail alerts: your consent for getting subscribed to our email alerts.

      e) Site maintenance: Almirall’s legitimate interest to provide you with the site without errors.

   6. Are we going to share your personal data?

      Data will not be shared with third parties other than our services providers who help us to better provide you with the information related to the Site (i.e. for instance, for data analytics), (hereinafter, the “Recipients”).

      Whenever information needs to be transferred to Recipients outside the European Economic Area to a country which has not received the decision of adequate level of protection issued by the European Commission, personal data will be duly protected by standard contractual clauses approved by the European Commission, or binding corporate rules of the data processor.

   7. Which are your rights as a data subject and how can you exercise them? The General Data Protection Regulation on data protection matters foresee that any individual can exercise the following rights before the data controller in connection with the processing of your personal data:

      Right of access: means the right to obtain access to your information that Almirall processes.

      Right to rectification: means the right to be entitled to have your information corrected if it is inaccurate or incomplete.

      Right to erasure: in simple terms, it means to request the deletion or removal of the information concerning him/her where there is no compelling reason for an organisation to keep using it. This right is also known as “the right to be forgotten” and is not a general right to erasure; there are exceptions.

      Right to restrict processing: means the right to ‘block’ or suppress further use of the information concerning You in certain circumstances. When processing is restricted, we inform you that Almirall can still store your information, but may not use it further.

      Right to data portability: means the right to obtain and reuse personal data by a third party in a structured, commonly used and machine readable format in certain circumstances. If you request the direct transfer of the data to another data controller, this will only take place if it is technically feasible.

      Right to object: means the right to object to certain types of processing, in certain circumstances.

      The exercise of the above referred rights would be applicable in accordance with the technical and organizational particularities of the corresponding data processing performed.

      The lawfulness of the data processing up to your consent withdrawal remains unaffected by the revocation. These rights may be limited in some situations – for example, where we can demonstrate we have a legal requirement to process your personal data.

      If you would like to exercise any of the abovementioned rights, you can send us an electronic request to our address datamanager.global@almirall.com, attaching a copy of your personal ID card/passport. Finally, we inform you that you can contact the Spanish Data Protection Agency or any European supervisory entity for any claim arising from the processing of your personal data. You can find an updated list of such organizations by jurisdiction at https://edpb.europa.eu/about-edpb/about-edpb/members_en

3. Notice for users in The United States of America.

   The California Consumer Privacy Act, the California Consumer Rights Act and other applicable Privacy-State laws in the USA provide consumers with specific rights regarding their Personal Information. This section describes your rights and explains how to exercise those rights. Please make sure you also consult our general privacy policy above for complete information.

   1. Access to Specific Information and Data Portability Rights

      You have the right to request that Almirall disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising your Rights section below), we will disclose to you:

      • The categories of Personal Information we collected about you.

      • The categories of sources for the Personal Information we collected about you.

      • Our business or commercial purpose for collecting or selling that Personal Information.

      • The categories of third parties with whom we share that Personal Information.

      • The specific pieces of Personal Information we collected about you (also called a data portability request).

      • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:

        • sales, identifying the Personal Information categories that each category of recipient purchased;

        • and disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

   2. Deletion Request Rights:

      You have the right to request that Almirall delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising your Rights section below), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

      We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

      • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

      • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

      • Debug products to identify and repair errors that impair existing intended functionality.

      • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

      • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.) or other similar applicable State-laws in the USA that we may be subject to.

      • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

      • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

      • Comply with a legal obligation.

      • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

   3. Right to correct inaccurate personal information

      You have the right to correct any inaccurate Personal Information about you (see Exercising your Rights section below).

   4. Right to limit use and disclosure of sensitive personal information

      We may collect certain sensitive personal information as allowable by law for purposes including analytics and/or to enable marketing to you, usually by means of cookies or similar technologies. You have the right to limit or to reject this activity by visiting our Cookies Policy and rejecting all the cookies in your device.

   5. Exercising your Rights

      To exercise the access, data portability, deletion rights and others described above, please submit a verifiable consumer request to us by any of the following methods:

      • Filling out the CCPA Data Access Request Form

      • Emailing us at dataprivacyus@almirall.com

      • Only you, or a person that you legally authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

      • You may only make a verifiable consumer request for access or data portability twice within a 12-month period. A verifiable consumer request must:

        • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

        • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

      • We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

      • Making a verifiable consumer request does not require you to create an account with us.

      • We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

   6. Response Timing and Format

      We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

      Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

      We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

   7. Personal Information Sales Opt-Out and Opt-In Rights

      You have the right to direct us to not sell your Personal Information at any time (the “Right to Opt-Out”). Users who opt-in to Personal Information sales may opt-out of future sales at any time.

      To exercise the Right to Opt-Out, you (or your authorized representative) may submit a request to us at: CCPA Data Access Request Form or to dataprivacyus@almirall.com.

      Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales at any time by contacting Almirall, LLC at the email address or phone number provided in this notice.

      You do not need to create an account with us to exercise your Right to Opt-Out. We will only use Personal Information provided in an opt-out request to review and comply with the request.

   8. Non-Discrimination

      We will not discriminate against you for exercising any of your rights. Unless permitted by law, we will not:

      • Deny you goods or services.

      • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

      • Provide you a different level or quality of goods or services.

      • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

   9. CALIFORNIA’S SHINE THE LIGHT LAW:

      We do not share your Personal Information with third parties for those third parties’ direct marketing purposes. California Civil Code Section 1798.83 permits California residents who have supplied Personal Information, as defined in the statute, to us to, under certain circumstances, request and obtain certain information regarding disclosure, of Personal Information to third parties for their direct marketing purposes. With any questions about the foregoing, please email us at dataprivacyus@almirall.com.