- what Personal Data we collect from you
- what we are doing with your Personal Data
- that we will only use your Personal Data for the purposes set out in this Data Protection Statement
- your rights, and how you can exercise control over your Personal Data
- not send you marketing emails if you do not want to receive them
- always ensure that we only share your Personal Data with third parties where absolutely necessary and with appropriate safeguards in place
- ensure appropriate technical and organisational measures are in place to protect your Personal Data and keep it secure
You can access our full Data Protection Statement below. In it we provide further information about what Personal Data we collect, what we use it for, why we collect it and what our legal basis is, who we share it with and how long we retain it. We also provide detailed information about your rights in relation to your Personal Data. If you have further questions, please get in touch with us using the contact details above. You have the right to lodge a complaint with a supervisory authority, in particular in the country where you reside, place of work or place of the alleged infringement if you consider that the processing of Personal Data infringes the GDPR.
The contact details for the Data Protection Commission (DPC) in Ireland are: Online Form: https://forms.dataprotection.ie/contact Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland Tel: +353 578 684 800 or +353 761 104 800.
Data Protection Statement For Uniphar
Contact DetailsA Data Protection Officer has been appointed. If you have any questions about this Data Protection Statement or the way in which your Personal Data is being used by us, please contact: Data Protection Officer C/O Uniphar PLC 4045 Kingswood Road, Citywest, Dublin D24 V06K Ireland Email:DPO@uniphar.ie
Personal Data“Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1. ABOUT USThis Data Protection Statement applies to the following companies in the Uniphar Group of companies: Uniphar PLC Allphar Services Ltd. Uniphar Wholesale Limited References to “We”, “Us” the “Company” and “Uniphar” shall apply to the company in the group that is processing your Personal Data. We are a trusted global partner to Pharma and MedTech manufacturers, working to improve patient access to medicines in Europe and around the world. We provide outsourced and specialised services to our customers. We’re growing by leveraging the strong relationships we have with 200+ of the world’s best known pharmaco-medical manufacturers across multiple geographies, enabled by our cutting-edge digital technology and our highly expert teams. We have several companies in our group which enable us to provide our services. These companies operate under their own Data Protection Statement available on their company websites. This Data Protection Statement applies solely to the companies in the group that are listed above. In order to provide our services, we need to process Personal Data. We are committed to protecting the rights and Data Protection of individuals in accordance with data protection legislation including the General Data Protection Regulation in Europe (the “GDPR”). We are committed to implementing the highest of data protection standards.
2. THE PURPOSE OF THIS DATA PROTECTION STATEMENTThis Data Protection Statement describes our approach to data protection and sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be used by us where we are controllers of that Personal Data for the purposes of the GDPR. Please read this Data Protection Statement carefully to understand our views and practices regarding the Personal Data we collect and how we will treat it.
3. WHO THIS DATA PROTECTION STATEMENT APPLIES TO?This Data Protection Statement provides specific information relating to the following individuals whose Personal Data we process:
- business contact data including our customers, suppliers, partners, shareholders, investors and business prospects “Business Contacts”; and
- prospective employees/those applying for jobs at the Company “Candidates”;
- users/guests of our Website “Website Users”.
4. CATEGORIES OF PERSONAL DATAWe process the following categories of Personal Data. For each category we have included an example of the type of Personal Data that may be part of that category:
|Personal Data Category||Description|
|Identification Data||may include a person’s name, photograph, date of birth, driver’s license and passport information.|
|Contact Data||may include a person’s email address, phone number, postal address, other communication details (e.g. Skype)|
|Communication Data||may include phone calls, email correspondence and hard copy correspondence.|
|Ecommerce Data||may include Contact Data, Communication Data, order history, account number, job position, invoice details, registration information.|
|Marketing Data||may include your Contact Data and any preferences in receiving marketing from us and your communication preferences.|
|Recruitment Data||may include recruitment related data such as Identification Data, Contact Data, Communication Data, CV and job application data. When processing CV data, we may process certain Personal Data including the following: employment history, skills/ experience, languages, educational history, qualifications, membership of professional associations, contact details of employer references/character references, licenses held, interests and hobbies, languages, locations, nationality, passport, eligibility to work in certain jurisdictions, salary expectations, interview/screening answers and notes and usernames and passwords for access to our recruitment portal.|
|Financial Data||may include payment related information or bank account details and financial data received as part of the services that we provide.|
|Special Category Recruitment Data||If we interact with you for the purposes of a job with the Company, we may collect Recruitment Data that is of a special category per the GDPR definition: this can include diversity data such as gender, religion, racial or ethnic origin, sexual orientation, trade union membership or data relating to health. We will only source this data with the explicit consent of Candidates.|
5. OUR LEGAL BASIS FOR PROCESSING PERSONAL DATAWe process all Personal Data lawfully and in accordance with the requirements of the law. The GDPR sets out the legal grounds for processing Personal Data. When the Company processes Personal Data, it is generally on one of the following legal bases: CONTRACT We will process Personal Data where necessary to perform our obligations relating to or in accordance with any contract that we may have with you or to take steps at your request prior to entering that contract (e.g. our Terms of Sale); CONSENT For certain processing activities we may rely on your consent. Where we are unable to collect consent for a processing activity, we will only process the Personal Data if we have another lawful basis for doing so. You can withdraw consent provided by you at any time by contacting us at email@example.com LEGITIMATE INTEREST At times we will need to process your Personal Data to pursue our legitimate business interests, for example for administrative purposes, to collect debts owing to us, to provide information to you, to expand our business opportunities, to operate, evaluate, maintain, develop and improve our websites and services or to maintain their security and protect intellectual property rights. We will not process your Personal Data on a legitimate interest basis where the impact of the processing on your interests or fundamental rights and freedoms outweigh our legitimate interests. You may object to any processing we undertake on this basis. If you do not want us to process your Personal Data based on our legitimate interests, contact us at firstname.lastname@example.org and we will review our processing activities. LEGAL OBLIGATION If we have a legal obligation to process Personal Data, such as the payment of taxes, we will process Personal Data on this legal ground.
6. OUR PROCESSING ACTIVITIESWe use your Personal Data to provide you with our services and to assist us in the operation of our Company. Under data protection law, we must ensure that the purpose of processing is clear. We have set out below the general purpose of processing, the categories of Personal Data processed and the related lawful basis for processing.
|Purpose of Processing||Categories of Personal Data||Lawful Basis|
|Service Delivery activities · to contact you re payments to and from you · for customer relationship management and support · to send notifications about changes/updates to our products and services · to fulfil our legal and contractual obligations||
- Identification Data
- Contact Data
- Communications Data
|· Contract · Legitimate Interest|
|Marketing & Promotion activities · to respond to any requests from you · to send newsletters and other information that maybe of interest · to contact you as part of our business relationship or for lead generation and general administration · to inform you of events or webinars that might be of interest · to deliver and organise our conferences, seminars, events||
- Marketing Data
- Contact Data
- Web Data
|· Consent · Legitimate Interest|
|Recruitment Activities · as part of agency shortlisting · to select the right Candidate · to interview the Candidate · to hire and seek to onboard the Candidate (pre contract) · to manage our database of prospective Candidates||
- Identification Data
- Contact Data
- Communication Data
- Recruitment Data
- Web Data
- Marketing Data
- Special Category Recruitment Data
|· Consent · Legitimate Interest · Contract · Legal Obligation|
|Website Delivery · to respond to web forms completed by you · to promote our products and services · to improve and administer the Website; and · for internal operations, including support, troubleshooting, data analysis, testing, research, statistical and survey purposes · to ensure the safety and security of our website and our services.||· Web Data||· Consent · Legitimate Interest|
|Ecommerce Services · to allow you to order products on the ecommerce section of the website · to process and deliver your orders · to process payments for products ordered · to allow you to see previous orders · to promote products that may be of interest to you · to ensure the security of the ecommerce service||· Ecommerce Data · Web Data · Marketing Data||· Legitimate Interest · Contract|
|Administration of Customer Relationship · to manage/respond to a complaint/appeal · to notify you of updates to this Data Protection Statement||· Identification Data · Contact Data · Communication Data · Financial Data||· Contract · Legitimate Interest|
|Managing payments and administration of the contract · to process payments to and from our business · to manage the contract||· Identification Data · Contact Data · Communication Data · Financial Data||· Contract · Legitimate Interest|
|Management of Corporate Affairs · to take minutes at board meetings · to contact shareholders/investors · to enter partnerships and other commercial relations · to undertake appropriate due diligence||· Identification Data · Contact Data · Communication Data · Financial Data||· Contract · Legitimate Interest · Legal Obligation|
7. SOURCES OF PERSONAL DATABUSINESS CONTACT PERSONAL DATA We collect Business Contact Personal Data from our business contacts including – customers, suppliers, partners, shareholders and business prospects. We source Business Contact Personal Data in order to serve the business relationship. We will only ever source Personal Data that is necessary and in a way that would be generally expected. We receive Personal Data about Business Contacts from a variety of sources, as follows:
- the Personal Data is often provided by the Business Contact as part of the business relationship;
- the Personal Data may be collected from public sources like LinkedIn;
- the Personal Data may be collected indirectly from another person within the company of the Business Contact;
- the Personal Data may be collected through our website;
- the Personal Data may be collected indirectly from a website or from a third party.
- the Candidate may send a speculative CV to us with the intention of registering with us to be informed of potential job vacancies;
- the Candidate may apply directly to a position advertised on our website;
- the Candidate may be referred to us from an agency or by an individual; or
- the Candidate may apply to a position advertised on a third-party jobs’ website.
8. DISCLOSURE OF PERSONAL DATAIn certain circumstances, we may disclose Personal Data to third parties as follows:
- to business partners and subcontractors for the performance of any contract relating to our services, including email, Skype, Communication Platforms, Customer Relationship Management system, web developers, payment processors, data aggregators, hosting service providers, external consultants, auditors, IT consultants and lawyers;
- to any recruitment agency who is helping us to recruit Candidates;
- to analytics and search engine providers that assist us in the improvement and optimisation of the Website;
- if we or substantially all our company is merged with another company or acquired by a third party, in which case Personal Data held by us will be one of the transferred assets;
- to other companies in the Uniphar group of companies for the purposes of administration, marketing, recruitment and provision of our services;
- if we are under a duty to disclose or share Personal Data in order to comply with any legal obligation (including tax, audit or other authorities), or in order to enforce or apply any contracts that we have;
- to protect our rights, property, or safety, or that of our Candidates or Business Contacts or others. This may include exchanging Personal Data with other companies and organisations for the purpose of fraud protection.
9. SECURITY MEASURESWe will take all steps reasonably necessary to ensure that all Personal Data is treated securely in accordance with this Data Protection Statement and the relevant law, including the GDPR. We have put in place appropriate technical and organisational procedures to safeguard and secure the Personal Data we process. We monitor for and do everything we can to prevent security breaches of the Personal Data that we process. Once we have received your Personal Data, we will use strict procedures and security features for the purpose of preventing unauthorised access and ensuring that only those who need to have access to your Personal Data can access it. We also use secure connections to protect Personal Data during its transmission. Where you have been given (or where you have chosen) a password which enables you to access services, you are responsible for keeping this password confidential. Please do not share your password with anyone. If you think that there has been any loss or unauthorised access to Personal Data of any individual, please let us know immediately.
10. TRANSFERS OUTSIDE THE EEAIn order to provide our products and services we may need to transfer Personal Data outside the European Economic Area (EEA). We ensure that any transfer of Personal Data outside the EEA is undertaken using legally compliant transfer mechanisms and in accordance with the GDPR. If we transfer Personal Data outside of the EEA, we generally rely on the Standard Contractual Clauses under Article 46.2 of the GDPR adopted by the EU Commission. We may also rely on some of the other legally compliant transfer mechanisms provided under the GDPR.
11. COOKIESCookies are small text files placed on your computer or mobile device by websites that you visit, and they help us improve the products and services that we offer you. They are used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies may allow a website to remember your activity over a period. Cookies are optional and you do not have to accept them. Further information on the cookies we use on the website and the purpose behind their respective uses are set out in our Cookie Notice.
12. THIRD PARTY WEBSITESOur Website may contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy settings, and these are not endorsed by us. We do not accept any responsibility or liability for these third-party websites. Please undertake the appropriate due diligence before submitting any Personal Data to these websites.
13. RETENTIONIn some circumstances it is not possible for us to specify in advance the period for which we will retain your Personal Data. In such cases we will determine the appropriate retention period based on balancing your rights against our legitimate business interests. We may also retain certain Personal Data beyond the periods specified herein in some circumstances such as where required for the purposes of legal claims. Further information about our retention practices are set out below:
|Purpose of Processing||Categories of Personal Data||Retention Period|
|Service Delivery Activities||· Identification Data · Contact Data · Communications Data||24 months after completion of service delivery activities in the case where there is no further meaningful engagement.|
|Marketing and Promotion Activities||· Marketing Data · Contact Data · Web Data||12 months in the case where no meaningful engagement or earlier in the case you unsubscribe.|
|Recruitment Activity||· Identification Data · Contact Data · Communication Data · Recruitment Data · Web Data · Marketing Data · Special Category Recruitment Data ·||12 months for Candidates who are not hired. Candidates who have consented will remain on the database for other positions with the company until consent is withdrawn or there is no meaningful engagement over a period. A separate retention policy applies to employees|
|Website Delivery||· Web Data||12 months|
|Ecommerce Services||· Ecommerce Data · Marketing Data · Web Data||12 months|
|Managing Payments and administration of the contract||· Identification Data · Contact Data · Communication Data · Financial Data||7 years|
|Management of Corporate Affairs||· Identification Data · Contact Data · Communication Data · Financial Data||7 years unless required to retain indefinitely|
14. YOUR RIGHTSYou have various rights relating to how your Personal Data is used. Right of access to the Personal Data we hold on you You have the right to ask for all the Personal Data we have about you. When we receive a request from you in writing, we must give you access to everything we’ve recorded about you as well as details of the processing, the categories of Personal Data concerned and the recipients of the Personal Data. We will provide the first copy of your Personal Data free of charge, but we may charge you a reasonable fee for any additional copies. We cannot give you access to a copy of your Personal Data in some limited cases including where this might adversely affect the rights and freedoms of others. Right of rectification of Personal Data You should let us know if there is something inaccurate in your Personal Data. We may not always be able to change or remove that Personal Data, but we will correct factual inaccuracies and may include your comments in the record to show that you disagree with it. Right of erasure of Personal Data (right to be forgotten) In some circumstances you can ask for your Personal Data to be deleted, for example, where:
- your Personal Data is no longer needed for the reason that it was collected in the first place
- you have removed your consent for us to use your Personal Data (where there is no other lawful basis for us to use it)
- there is no lawful basis for the use of your Personal Data
- deleting the Personal Data is a legal requirement
- we are required to have it by law
- it is used for freedom of expression
- it is used for public health purposes
- it is used for scientific or historical research or statistical purposes where deleting the Personal Data would make it difficult or impossible to achieve the objectives of the processing
- it is necessary for legal claims.
- you have identified inaccurate Personal Data, and have told us of it
- where we have no legal reason to use the Personal Data, but you want us to restrict what we use it for rather than erase the Personal Data altogether
15. AMENDMENTS TO THIS DATA PROTECTION STATEMENTWe will post any changes on the Website and when doing so will change the effective date at the top of this Data Protection Statement. Please make sure to check the date when you use our services to see if there have been any changes since you last used those services. In some cases, we may provide you with additional notice of changes to this Data Protection Statement, such as via email. We will always provide you with any notice in advance of the changes taking effect where we consider the changes to be material. Thank you for reading our Data Protection Statement. Please contact us at email@example.com if you have any questions. If we are unable to resolve your concerns, you have the right to contact the supervisory authority in the country where you live or work, or where you consider that the data protection rules have been breached. Contact Details for the relevant Supervisory Authorities are set out below for your information:
|Country||Supervisory Authority||Contact Details|
|Ireland||Data Protection Commission||
Online Form: https://forms.dataprotection.ie/contact Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
Tel: +353 578 684 800 or +353 761 104 800