Privacy Policy of Social Networking Services

Attachment to the Regulations of Social Media Services USP Zdrowie sp. z o.o.

Who is the Administrator of your personal data?

USP Zdrowie operates with respect for the privacy of individuals visiting its profiles on websites such as www.facebook.com, www.youtube.com, www.instagram.com, www.linkedin.com, www.twitter.com websites and protects their personal data, hereinafter referred to as Social Services.

As a rule, the administrators of personal data processed within social networking sites are their owners. We refer you to the relevant websites of these services.
To a certain extent described below in the Terms (e.g., collecting information on adverse effects by Social Networks, sending or receiving messages, conducting chats and video chats), the data administrator is the entity that created the profile on the given Social Network.
In our case, the administrator of personal data of people visiting Social Networks belonging to USP Zdrowie sp. z o.o. is USP Zdrowie sp. z o.o., based in Warsaw, 02-822 Warsaw, ul. Poleczki 35.

USP Zdrowie sp. z o.o. is registered in the register of entrepreneurs maintained by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register under the number KRS 0000347815, and uses the following identification numbers: NIP 7010219241, REGON 142269887.

In the case of reporting adverse reactions to medicinal products, the administrator of your personal data is US Pharmacia sp. z o.o. with its registered office in Wrocław, 50-507 Wrocław, ul. Ziębicka 40.

US Pharmacia sp. z o.o. is registered in the register of entrepreneurs maintained by the District Court for Wrocław-Fabryczna in Wrocław, VI Commercial Division of the National Court Register under the number KRS 0000046646, and uses the following identification numbers: NIP 8991432896, REGON 011213010.

If you wish to contact USP Zdrowie sp. z o.o. or US Pharmacia sp. z o.o. regarding matters related to the processing of personal data, please:

1. sending an email to the address: [email protected];
2. sending a letter to the address: USP Zdrowie sp. z o.o., ul. Poleczki 35, 02-822 Warszawa or US Pharmacia sp. z o.o. ul. Ziębicka 40, 50-507 Wrocław.

This Policy applies to the extent it does not conflict with the regulations of www.facebook.com, www.youtube.com, www.instagram.com, www.linkedin.com, www.twitter.com or other social media services.

As part of the Social Networks Privacy Policy, we want to provide you with information related to the activities we undertake regarding the processing of personal data collected through our Social Networks. In the document, we also present information about the principles of using your data within the services available through our Social Networks. We also want to provide you with information regarding the rights related to the processing of personal data.

Our Privacy Policy takes into account the requirements arising from the provisions of Regulation (EU) 2016/679 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). In further sections of the Privacy Policy, we will refer to this legal act using the abbreviation “GDPR”.

Before starting to use the Social Services, each User should familiarize themselves with this Privacy Policy.

Scope of data collection, purposes of processing, and legal bases

Within the Social Media Services, we may collect your personal data to enable the submission of reports on adverse drug reactions, answer questions regarding the operation of our products or complaints, provide the User with guidance, useful information, news about USP Zdrowie products and services and about USP Zdrowie company or other companies in the USP Zdrowie Group.

Reporting adverse events via comments or messages on Social Networking Services

In your comments or messages sent to us via Social Media Services, there may be information constituting reports of adverse effects of medicinal products.

The administrator of personal data contained in the aforementioned comments or messages, including in particular the patient’s identification data (initials, age/date of birth, gender), reporting person’s identification data (first name, last name, address, phone number, email address, specialization), description of adverse event, is the responsible entity, i.e., US Pharmacia sp. z o.o.

Providing personal data by persons obligated to report adverse drug reactions (e.g., doctors) is mandatory and results from the relevant provisions of the Pharmaceutical Law Act of September 6, 2001, and other legal regulations.

In the case of other individuals, providing personal data is voluntary but necessary for the acceptance of the application. You also have the option to report an adverse event by calling the phone numbers listed on the website www.uspzdrowie.pl or by contacting the Office for Registration of Medicinal Products, Medical Devices, and Biocidal Products.

US Pharmacia processes your personal data for purposes related to the fulfillment of the obligation to monitor the safety of medicinal products (Article 6(1)(c) GDPR). In the case of special categories of personal data, such as health data, US Pharmacia processes your data based on the necessity for reasons of public interest in the area of public health, such as ensuring high standards of quality and safety of medicinal products (Article 9(2)(i) GDPR). The legal basis for processing the personal data mentioned above is the provisions of the Pharmaceutical Law Act of September 6, 2001.

Contact forms with USP Zdrowie or contact by phone or through messages

Posted on the Social Media Services pages, the contact forms allow you to send messages to USP Zdrowie on various issues (e.g., complaints, invoices, settlements, product availability, advertising of our products, contacts with our employees, USP Zdrowie company or companies from the US Zdrowie Group).

You can also contact us by calling the phone numbers provided in the Social Services or by sending us messages through these Services to the provided email addresses.

Providing contact information, such as your name and email address, is completely voluntary, but necessary to enable us to contact you.

We process personal data in order to contact you in connection with the inquiry we received. The legal basis for processing this type of personal data is the necessity for the performance of a contract for the provision of electronic services (Article 6(1)(b) of GDPR).

Chats or videochats with USP Zdrowie experts

In Social Services, we can conduct so-called chats or video chats that allow Users to ask medical questions to internal or external USP Zdrowie experts regarding USP Zdrowie products or health.

You also have the option to ask the aforementioned questions by calling the phone numbers provided on Social Media Services or on the website www.uspzdrowie.pl.

Providing us with contact information is voluntary, but necessary for our experts to be able to answer your question.

Your personal data is processed for the purpose of responding to questions addressed to the experts. The legal basis for processing this type of personal data is the premise of necessity for the performance of a contract for the provision of electronic services (Article 6(1)(b) of the GDPR).

During chats and video chats, adverse effects of medicinal products can also be reported. In such cases, see Reporting adverse effects through comments or messages on Social Media Services.

Searching for candidates for work in the companies of the USP Zdrowie Group

Through the website www.linkedin.com, we contact selected individuals for recruitment purposes to be employed in companies within the USP Zdrowie Group. We then process your personal data that you have placed on your profiles on this service. This data will be used solely for the purposes of conducting recruitment, and upon successful completion, for entering into an employment contract (legal basis for processing: Article 6(1)(b) of the GDPR);

Detailed rules for personal data processing in the recruitment process can be found on the page https://www.uspzdrowie.pl/kariera/

Statistical activities, ensuring safety by USP Zdrowie

Within the Service, we may collect personal data regarding your activity, such as: behavior on the site, actions taken, IP address, login location. The above personal data will be used for internal statistical purposes and the development of the services we provide. The collected information will also be used to ensure IT security.

The legal basis for processing this type of personal data is the legitimate interest of the administrator (Art. 6 para. 1 lit. f GDPR) consisting in the improvement of Social Services, in order to provide the User with the highest quality services.

Marketing (offers, promotions, newsletter) USP Zdrowie

Your personal data is also used by us for marketing purposes, involving the promotion of our goods and services. As part of our marketing efforts, we may also encourage you to familiarize yourself with the offers of our business partners.

As part of our marketing activities, we send Users messages containing information about new products or services (newsletter).

We emphasize that receiving commercial information such as offers, promotions, or newsletters occurs only if you have given separate consent for marketing communication, which can be withdrawn at any time. Withdrawal of consent is possible via the link included in every email containing marketing messages or by sending an email to: [email protected]

The personal data we collect may be used to create so-called User profiles, based on their interests and activity on Social Media Services. Based on these profiles, we send more tailored marketing messages informing about our products.

The legal basis for our processing of this type of personal data is the legitimate interest of the administrator (Art. 6(1)(f) GDPR) consisting of conducting marketing activities.

Enforcement of Compliance with the Regulations, including Combating Fraud and Abuse by USP Zdrowie

In connection with the concern for the interests of our Users, personal data collected within Social Media Services are also used to monitor compliance of individual activities with the provisions of the Terms of Service and to combat fraud.

The legal basis for our processing of this type of personal data is the legitimate interest of the administrator (Art. 6(1)(f) GDPR), which involves combating undesirable phenomena and preventing fraud.

Establishing and Pursuing Claims by USP Zdrowie

In some cases, the personal data we collect may be processed to establish and pursue claims regarding your use of our services as part of using Social Media Services.

The legal basis for processing in this case will be the legitimate interest of the administrator (Article 6(1)(f) GDPR), consisting of the necessity to establish, pursue, and enforce claims, as well as to defend against claims.

IP Address and Cookies

As part of operating Social Services, USP Zdrowie collects data using cookie technology. Cookies („cookie”) are small text files that store data locally on a computer or other device.

Via cookies, the website server has the ability to save information, e.g., about preferences and settings of a computer or another device, which are replayed during the next visit. In other words, cookies enable a user-friendly experience of Social Services so that it is possible, for example, to use it without having to log in again. Both “persistent” and “session” cookies are collected. “Persistent” cookies are stored on the User’s computer for a longer period, while “session” cookies are automatically deleted after closing the browser window.

Data processing in the form of cookie files is based on consent given through web browser settings (Art. 6(1)(a) GDPR) for statistical purposes, service development, and marketing purposes (displaying ads on websites).

In Social Media Services, cookies are also used by USP Zdrowie’s partners to enable the personalization of advertising activities and evaluate their effects. These include Facebook and Google Analytics. You can opt out of cookies sent by Google Analytics at: https://tools.google.com/dlpage/gaopto. You can opt out of cookies sent by Facebook or other USP Zdrowie partners at http://www.aboutads.info/choices and http://www.youronlinechoices.eu/.

Recipients of personal data

In connection with the processing of personal data for the purposes indicated above, your personal data may be shared with the following recipients or categories of recipients:

1. suppliers supporting our services (e.g., IT support, web developers, hosting companies, marketing agencies, marketing tool providers);
2. companies providing courier services;
3. other companies belonging to the USP Group to the extent justified by corporate requirements,
4. to the competent public authorities acting on the basis of relevant legal provisions.

Period of personal data storage

Your personal data is stored for the period necessary to achieve the purposes of processing (e.g., for the period of maintaining the account, the period necessary to handle submissions and complaints) and as required by applicable regulations (e.g., the period necessary to handle and store reports of adverse drug reactions).

When assessing the period necessary to achieve our goals, we take into account the nature of the data (including the nature of special categories of data), its scope, and the context of processing. We also consider the provisions of applicable laws that require us to continue processing personal data. We also keep in mind the potential risk of unauthorized use or unauthorized disclosure of your personal data.

Personal data related to cookie technology is stored for a period corresponding to the cookie life cycle of 14 months or until they are deleted by the User.

Rights related to the processing of personal data

As part of the Social Services, we provide you with the exercise of rights concerning the processing of personal data.

In relation to the processing of personal data, you are entitled to the following rights:

Right of access to data (Art. 15 GDPR)

At any time, you have the right to obtain confirmation from us as to whether we are processing your personal data. If this is the case, you are entitled to:

1. obtaining access to your personal data;
2. obtaining information on the purposes of processing, categories of processed personal data, recipients or categories of recipients of personal data, planned data retention period or criteria for determining this period, rights under the provisions of the GDPR, and the right to lodge a complaint with the competent supervisory authority, sources of data origin;
3. obtaining a copy of your personal data.

Right to rectification of data (Article 16 GDPR)

At any moment, you may request us to rectify or complete your personal data that you have provided. For some of the services we offer, the exercise of this right can be done by independently changing the data within account management. You may also request us to rectify or complete other types of data by contacting us via email, in writing, or by phone.

Right to erasure (Art. 17 GDPR)

You have the right to request the deletion of all or some of your personal data. In cases where the services provided by us include the possibility of account creation, the request to delete all personal data will be treated by us as a request to delete the account.

The right to request the deletion of personal data applies to you if:

1. data are no longer necessary for the purposes for which they were collected or otherwise processed;
2. an objection to the processing of personal data has been raised;
3. the consent on which the processing is based has been withdrawn, and there is no other legal basis for processing;
4. data are processed unlawfully;
5. data must be deleted in order to fulfill an obligation arising from legal regulations.

The right to delete personal data is not absolute. Administrators may retain certain categories of personal data to the extent required by law, or necessary to establish, pursue, or defend claims.

Right to restriction of data processing (Art. 18 GDPR)

In connection with the processing of personal data, you have the right to restrict it when:

1. you question the accuracy of personal data;
2. processing of data is unlawful, and you object to the erasure of data, requesting instead that its processing be restricted;
3. we no longer need the data for our purposes, but you need them to establish, defend, or pursue claims;
4. an objection to data processing has been raised – we will limit data processing until it is determined whether the legitimate grounds on the part of the controller override the basis of the objection.

The right to data portability (Art. 20 GDPR)

You have the right to receive personal data that you have provided to us and to transfer it to another data controller of your choice. The right to portability applies when we process personal data based on consent or for the performance of a contract, and the processing is carried out in an automated manner, i.e., in IT systems. For this purpose, we will provide you with a copy of the data in a computer-readable file format (e.g., CSV, Excel).

You may also request that the personal data be sent by us directly to such an administrator. We reserve the right to fulfill such a request if it is technically possible.

The right to object (Article 21 GDPR)

At any time, you have the right to object to the use of personal data if we process the data based on the legal grounds of legitimate interest (Article 6(1)(f) of the GDPR).

In the case of processing your personal data for marketing purposes, objection will exclude you from marketing operations, including profiling and sending marketing communications. Please remember that displaying advertisements within Social Media Services is based on consent to the use of cookies. To stop receiving cookie-based ads, it is necessary to change your browser settings.

The right to withdraw consent (Art. 7 GDPR)

You have the right to withdraw any consent granted during the use of Social Media Services, as well as when using other services provided by us. Please remember that the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

The right to lodge a complaint with a supervisory authority

In connection with the processing of personal data, you may file a complaint with the competent supervisory authority (President of the Personal Data Protection Office).