vocate pharmateuticals s.a.

Personal Data Protection Policy

Introduction

The company VOCATE Pharmaceutical S.A. respects and protects your privacy and personal data. In the course of its activities and in full compliance with applicable legislation, it may process your personal data. VOCATE is committed to protecting your personal data during any processing. The present Privacy Policy defines the types of personal information we collect, the methods by which we collect and process such information, to whom we disclose it in relation to the services we provide, and certain rights and choices you have regarding this information.

This Personal Data Protection Policy provides information on how VOCATE processes the data that concerns you.
The Personal Data Protection Policy, which is available on this website, is regularly updated to reflect legislative and regulatory changes, as well as any changes in VOCATE's organization or the processing we perform. Our website may include links to third-party websites/content/services that are not owned or controlled by VOCATE. VOCATE is not responsible for how such third parties use or handle your personal data. Therefore, we recommend that you carefully read their policies and terms regarding personal data protection.

In addition to this Personal Data Protection Policy, specific information is provided for each processing activity we carry out concerning your personal data. This information is provided as soon as possible and, in the case of direct collection of your data, at the time of collection.

    I - Data Controller

    VOCATE Pharmaceutical S.A. is, under the applicable law (Article 4, paragraph 7 of the GDPR), the Data Controller of your personal data within the framework of the present Privacy Statement, and when acting as the data controller, it is responsible for the personal data you provide to us.

    For the purposes of applicable data protection law (specifically the General Data Protection Regulation (GDPR) 2016/679 of the EU or the <> and Law 4624/2019, which incorporates the GDPR into the Greek legal system), your data will be processed by VOCATE or its subsidiaries, or by a company providing services to you or communicating with you. Each of the aforementioned companies will be considered an independent data controller of your personal data. The present Privacy Policy applies to all such entities.

    II - What are our commitments

    We are committed to ensuring the highest possible level of protection for the personal data of individuals whose personal data we process (the "data subjects"), as well as any other personal data.

    We are committed to complying with the regulations applicable to all types of personal data processing that we carry out. Along the same lines, we undertake the obligation to adhere to the following principles:

    • We process your personal data in a lawful, fair, and transparent manner.
    • We collect your personal data for specific, legitimate, and clear purposes and do not intend to process them in a manner that is incompatible with such purposes.
    • We ensure that the personal data being processed is adequate, relevant, and limited to what is necessary for the purposes for which it is being processed.
    • We make every effort to ensure that the personal data being processed is accurate and, where necessary, kept up to date. We will take all reasonable measures to ensure that inaccurate personal data, in relation to the purposes for which it is processed, will be deleted or corrected promptly.
    • We retain your personal data in a form that allows you to be identified for no longer than is absolutely essential for the purposes for which the data is being processed.
    • We process personal data in a way that ensures its security.
    This last commitment is reflected in the following:
    • We respect your privacy and rights.
    • We guarantee that the protection and security of personal data are at the forefront of our attention.
    • We deal with every new processing activity with a focus on data protection principles, in order to achieve the protection of personal data by design.
    • We will not use your personal data for purposes for which you have not been informed.
    • We do not believe that your data should be stored for long periods of time.
    • We will not disclose or sell your data in ways not described in this Data Protection Policy.
    • We are committed to ensuring and protecting your personal data.
    • We respect your personal data as data subjects and as individuals, and we will make every effort to fulfil your request when possible
    • We will send you commercial communications only if you have requested them or to offer similar products or services, provided we have obtained your electronic details in accordance with Directive 95/46/EC. You reserve the right to change your mind and opt out of such commercial communications through a very simple process.

    III – What personal data do we collect

    Personal data refers to information that relates to an identified or identifiable natural person ("data subject"), such as email address, full name, IP address, etc.
    We collect your personal data through this website, as well as through other means. In some cases, we collect your personal data directly from you. In other cases, your personal data is provided to us by a third party.

    VOCATE ensures that it collects and processes only the personal data that is absolutely essential for the purposes for which it is being processed. For every processing activity we carry out regarding your personal data, you will be informed as soon as possible about the categories of personal data we are processing.

    The personal data we collect includes, but is not limited to:

    • identifying information, personal details, and contact information, such as full name, address, phone number, marital status, IP address, etc., in the context of the company's operations, fulfilling its purposes, and legal obligations
    • data from applications, such as CVs, diplomas, professional experience, and skills, when you submit, for instance, an application for a job position at VOCATE or its subsidiary
    • business information, including information provided during any contractual relationship or supplier-customer relationship between you or your organization and VOCATE, or information voluntarily provided by you or your organization in another manner
    • professional datasuch as job title and skills, for the management of our suppliers and service providers
    • financial data and payment data, including your bank account information and other details required for processing payments and combating fraud, such as credit/debit card numbers, security code numbers, and other relevant billing information.
    • Image capture data,, collected from closed-circuit television (CCTV) systems.
    • entry/exit log data at the company's facilities for the purpose of ensuring the security of individuals, property, and premises.
    If you submit personal data concerning other individuals, you declare that you have the right to do so and allow us to use such information in accordance with the present Personal Data Protection Policy.

    IV – For what purposes are your personal data being processed

    The data processing activities carried out by VOCATE serve specific, legitimate, and defined purposes.

    The data is processed in order to serve you. Indicatively, we use your personal data for the following purposes:

    • to carry out our our business activities,
    • In case you apply for a job position, we may process your personal data in order to manage your application,
    • to deliver the products and services you purchase and to process, fulfil, and complete the transactions you request,
    • to provide services to our customers, to respond to your requests or inquiries, and to communicate with you,
    • to tailor our marketing programs, reward programs, as well as our campaigns,
    • to send you newsletters, articles, warnings, announcements, invitations to scientific events, and other information regarding products, brands, health topics, and pharmaceutical interests,
    • if you are our supplier, service provider, or an employee of our supplier or service provider, we may process your personal data for the purpose of managing our suppliers and service providers in accordance with applicable laws and regulations,
    • for the purpose of managing our relationship with you when you are, for example, a prospective or registered user of our website. We may process profile and usage data, including login credentials for VOCATE websites or platforms/services with password protection, your preferences regarding the receipt of commercial information from us, your communication preferences, and information about how you use our website(s), including the services you viewed or searched for, page response times, download errors, duration of visits, and interaction information with the page (e.g., scrolling, clicking, and mouse hovering). Information about other persons: If you provide us with information regarding other persons besides yourself, e.g., your employees, counterparties, consultants, or suppliers, you must ensure that they understand how their information will be used, that they have given you permission to disclose it to us, and that they allow us, as well as our external providers, to use it.
    For each processing activity we carry out with your data, the purpose of the processing will be communicated to you on a case-by-case basis.

    V – How we ensure that the processing activities we carry out are lawful

    When we process personal data that concerns you, we always ensure that the processing has a 'legal basis' (i.e., that the processing takes place for the purpose of performing a contract or that we have your consent, etc.). Legal basis means that the processing meets the strict requirements of the GDPR and, therefore, is considered lawful.

    We process your personal data always in accordance with the following legal basis.

    • When you enter into a contract with us, under which we are required to process your data, the legal basis for the processing is the performance of the contract.
    • When the processing is required for the purpose of taking measures at your request, before entering into an agreement, the legal basis for the processing is the taking of such measures. For example, this applies if you submit your application for a job position, which requires us to review your CV in order to make a decision regarding your application.
    • When you provide your consent to the processing of your personal data for one or more specific purposes, the processing on our part is justified by your consent. This is the case for the processing of your personal data by us during the conduct of scientific research. When we use the consent you provide as the legal basis for processing, you are free to withdraw it at any time.
    • Where the processing serves the legitimate interests of us or third parties (unless these interests are overridden by your interests or fundamental rights and freedoms, which require the protection of your personal data, particularly if you are a child), the legal basis is the aforementioned legitimate interests. For instance, the processing of your personal data for the purposes of direct marketing may be considered to serve a legitimate interest, even if it involves direct commercial promotion, although in some cases, your consent may be required.
    • Additionally, we may process your personal data under any legal basis referenced in the applicable legislation or regulation. For more information on the subject, reference is made to Article 6.1 of the GDPR, which lists all possible legal bases.
    The legal basis for every processing activity we carry out with your data will be communicated to you on a case-by-case basis.

    VI – For how long do we retain your data

    VOCATE will retain your personal data only for as long as necessary to fulfil the purposes for which they are processed and in accordance with applicable law. Therefore, the retention period of personal data depends on the purpose served by each processing activity.

    The determination of the retention period for your data also depends on the following criteria:

    • If cookies are used, we set the lifespan of the cookies in accordance with the limits defined by the competent national supervisory authority.
    • When we retain certain personal data in order to fulfil our legal or regulatory obligations and exercise our rights, such data is retained for the period defined, if specified, in the relevant legal reference (e.g. Limitation period or legal data retention period)."
    The data retention period will be communicated to you on a case-by-case basis.

    VII – Who has access to your personal data

    Authorized individuals working for VOCATE have the right to access your personal data. We make every effort to ensure that these groups of people remain as limited as possible and to maintain the confidentiality and security of your data.

    Depending on the type of processing, the data may also be received by third-party recipients, such as our trusted providers who support our business operations.
    In this context, we provide our trusted providers only with the information they need to provide the service and requesting them not to use your personal data for any other purpose. We always make every effort to ensure that the trusted service providers we work with will guarantee the confidentiality and security of your data. Additionally, we ensure that when our relationship with a trusted service provider ends, the latter erases your data immediately.

    We select our trusted service providers with special care, ensuring that they provide adequate guarantees, particularly regarding their know-how, reliability, and resources, in order to implement technical and organizational measures that meet the requirements of applicable law, including processing security. At the same time, we ensure that our trusted providers process personal data in accordance with our documented instructions. What is more, we ensure that their staff is committed to maintaining confidentiality or is subject to a regulatory obligation of confidentiality.

    We may ask our trusted service providers to provide services that require the processing of your personal data, such as in the following cases:

    • the hosting of our website,
    • the storage of our data,
    • the maintenance of our devices/software,
    • the use of applications and collaborative tools that we have provided our employees with.
    We will inform you about the identity or role of our trusted providers for every processing activity we carry out on your personal data.

    We may need to disclose or share your personal data in order to comply with a legal obligation, enforce or apply the terms of use/sale or any other conditions you have accepted, or to protect the rights, safety, or property of VOCATE, its customers, or its employees.

    For instance, we may need to disclose your details to third parties as follows:
    • To law enforcement agencies and regulatory authorities or other competent authorities in accordance with legal requirements or best practices.
    • To the appropriate interested parties in case of emergency: primarily with the aim of safeguarding the health and safety of our customers, staff, and organizations
    • To your company or your organization, which maintains a business relationship with us.
    • To service providers for auditing purposes, in order to comply with legal obligations related to crime prevention and control (including but not limited to corruption and related offences)
    • To advertising networks and analytics service providers, in order to support and display advertisements on our website, in applications, and other social media tools.
    • To third parties in the context of the acquisition or transfer of any part of our business operations or any restructuring thereof.
    • To other interested parties: when your name appears on a participant list for events which you have informed us you intend to attend

    VIII – Where we store your data

    Your data is stored by VOCATE and its trusted service providers within the European Economic Area (EEA).

    Your personal data is not transferred to third countries (i.e., countries outside the European Economic Area), unless you have given us your written consent, or the transfer is required by law or, finally, when the transfer is necessary for the performance of our contractual obligations. The data protection laws in the countries to which your personal data is transferred may not be equivalent or may not provide the same level of protection as the laws in force in Greece or the EU. In such cases, our company ensures that the data controllers or processors in third countries comply with European data protection standards and provide appropriate safeguards regarding the transfer of your data in accordance with Article 46 of the GDPR.

    IX – What Are Your Rights as Data Subjects and How Can You Exercise Them

    Provided it is stipulated by data protection laws or regulations, when your personal data is processed by one of the affiliated companies within the EU, or by an affiliated company based in a different jurisdiction where similar rules apply, you have certain rights regarding your personal information. These rights derive from the GDPR (Articles 15–22) and the applicable legal framework. The ability to exercise these rights, as well as the ways in which you can use them, are described in more detail below. Some of these rights will apply only in specific circumstances.

    Depending on the type of processing, you have:

    • The right to obtain confirmation from us as to whether your personal data is being processed (right of access). In this case, you may access your personal data and request information, such as the purpose of processing, the relevant categories of personal data, etc.
    • The right to require us to correct inaccurate personal data concerning you (right to rectification).
    • The right to obtain the deletion of your personal data from us, provided that one of the grounds justifying this right applies (right to erasure).
    • The right to obtain the restriction of processing, provided that one of the grounds justifying this right applies (right to restriction of processing).
    • The right to receive your personal data in a structured, commonly used, machine-readable format and the right to transmit such data to another data controller without objection from us (right to data portability).
    • The right to in other words, to object to the use of your personal data.
    • The right to set guidelines for the processing of your personal data following your death.
    If you wish to exercise or discuss any of these rights, please contact the relevant authority at the contact address indicated in the present Personal Data Protection Policy.

    In order to process your request effectively, you will need to verify your identity in any way. In case there is any doubt on our part, we may request additional information, specifically a copy of your identity card signed by you.

    We will make every effort to adequately respond to your requests. In any case, we will respond to you within one month. Our response time may be extended by two months, depending on the complexity and number of your requests.

    If for any reason you believe our response is unsatisfactory, we inform you that you have the right to file a complaint with a supervisory data protection authority in the Member State of the European Union where you normally reside, where we are established (the Hellenic Data Protection Authority – HDPA), or where the alleged violation of the Data Protection Law has taken place.

    X – What Kind of Information will we provide You

    Each time VOCATE processes your personal data, it will inform you about the following, providing you with:

    • the identity and contact details of the data controller (i.e., the entity that determines the purposes and means of processing your personal data) and, where applicable, its representative,
    • the contact details of the data protection officer;
    • the purposes for which the processing of personal data serves, as well as the legal basis for the processing,
    • the legitimate interests of VOCATE or a third party, if applicable,
    • the recipients, or categories of recipients, of the personal data, if applicable,
    • Where necessary, you will be informed about VOCATE's intention to transfer personal data to a third country or international organization, the existence or absence of an adequacy decision by the Commission, or, where applicable, a reference to the appropriate or suitable safeguards and the means to obtain a copy of them or where they are made available,
    • the period for which the personal data will be stored or, if that is not possible, the criteria used to determine that period,
    • your right to request access to your personal data, correction or deletion of them, or to restrict the processing of your data, or to object to the processing, as well as the right to data portability,
    • where applicable, the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent before it was withdrawn,
    • the right to lodge a complaint with a supervisory authority,
    • if the provision of personal data is a legal or contractual requirement, if it is a condition for entering into an agreement, and if you are obliged to provide the personal data and if there are any consequences if you do not do so,
    • the existence of any automated decision-making, including profiling, and at least in these cases, meaningful information about the logic involved, as well as the significance and the foreseeable consequences of such processing for you,
    • if the data was not obtained directly from you, the relevant category of personal data, the source from which the personal data originates, and, where applicable, whether the data came from sources accessible to the public.
    The above information will be provided to you as soon as possible and, in the case of direct collection of your data, at the time of collection.

    XI – How we handle security

    VOCATE places great importance on the protection of your personal data and, for this reason, takes all reasonable precautions. We ask the partners who manage your data on our behalf to do the same.

    We continuously make every effort to protect your personal data. Following reception of your data, we apply strict procedures and take security measures (both technical and organizational) to prevent any unauthorized access. Since the transmission of data over the internet is not completely secure, we cannot guarantee the security of your data transmitted to our website. Therefore, any such transmission is done at your own risk.

    XII – Cookies

    We use cookies that identify your browser. When you visit our website, they collect and store information regarding how you use it. Through this information, it is possible to record how the website is used, as well as to provide you with improved service and experience during your browsing. The aforementioned information is also used for analysis purposes.

    The personal data we collect through these technologies will also be used to manage your stay on our website.

    As defined in Chapter VI of the present Personal Data Protection Policy, we set the duration of cookies under the limits provided by the competent national supervisory authority.

    XIII – links to third-party websites

    Our website, newsletters, email updates, and other communications may, from time to time, contain links to and from third-party websites. The personal data you provide on these websites is not subject to the present Personal Data Protection Policy, and their processing by such websites is not our responsibility.

    If you follow links to other websites, please note that these websites have their own privacy notices with detailed information on the collection and processing of your information when you visit them.

    XIV – Children

    We do not knowingly collect information from children or individuals under the age of 16. If you are under 16 years old, you have the right not to provide personal data, except for those required for specific training purposes or in the case of security access with explicit written parental consent.

    XV – Amendment of the present Personal Data Protection Policy

    The present Personal Data Protection Policy may be amended from time to time.

    In the event of significant changes to this Policy (regarding the type of information we collect, the methods, and reasons for collection), these will be highlighted at the top of the notice, and a visible link to them will be provided for a reasonable period following their adoption.

    XVI – Contact Details

    If you have any questions or requests regarding the present Personal Data Protection Policy (Data Protection Statement), or if you wish to exercise your rights, please contact the Company's Data Protection Officer (DPO) using the contact details below:

    E-mail:info@vocate.gr

    Postal address:150 Gounari st, P.C. 166 74 Glyfada, Athens

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