Privacy Policy

Introduction

Welcome to the website “www.crosspharma.gr”, an online platform owned and managed by the private capital company named “CROSS PHARMACEUTICAL COMPANY PRIVATE CAPITAL COMPANY”, with the trade name “CROSS PHARMACEUTICALS P.C.”, headquartered in Thessaloniki (KOSTI PALAMA 4, PYLAIA, PYLAIA / THESSALONIKI, 55535), with VAT number 998033328, Tax Office: Z Thessaloniki (hereinafter referred to as “we” or “the Company” or “CROSS”).

The use of our aforementioned website (hereinafter the “Website”) is subject to the Terms and Conditions of Use (hereinafter the “Terms of Use”) and this Privacy Policy. The Privacy Policy has been updated to ensure compliance with Regulation (EU) 2016/679 General Data Protection Regulation (hereinafter “GDPR”), Law 4624/2019 implementing it, and the relevant recommendations and guidelines of the competent supervisory authorities, and generally with the applicable legislation on the protection of personal data, as in force.

By using the Website, you declare that you have reviewed, understood, and accepted all the terms included in the Terms of Use and the Privacy Policy. If you do not agree with any of the terms contained in the Terms of Use and/or the Privacy Policy, you should refrain from visiting and using the Website.

The Privacy Policy may be subject to modifications and adjustments from time to time, whenever deemed necessary and without prior notice to you, which will apply from the date they are published on the Website. We encourage you to regularly review the Privacy Policy.

The Privacy Policy describes how CROSS, as the “Data Controller” within the meaning of the GDPR, collects and processes your personal data and other information about you, the users of the Website, as well as how our Website uses cookies and any other recognition technologies.

Purpose of the Privacy Policy

The Company ensures the confidentiality of your personal data. The Privacy Policy helps you understand, among other things:

The purpose for which we process your personal data
The categories of your personal data we collect and process
The retention period of your personal data
The categories of recipients of your personal data, if any
Whether we intend to transfer such data to a country outside the European Union (EU)/European Economic Area (EEA)
Whether we make automated decisions or profiling
Your rights regarding the processing of your personal data and how you can exercise them

The Privacy Policy is categorized for your convenience into the following distinct sections/chapters.

1. When and Why We Collect and Process Your Personal Data

Most of the personal information we process is provided directly by you.

When you contact us directly for any reason (e.g., via our Website or through the other contact details listed therein). In this case, we process your data in order to respond to your inquiry.

When you submit a complaint or report regarding any suspected incident that has come to your attention and is related to CROSS pharmaceutical products. In this case, we process your data in order to address your complaint/report, as well as for the lawful pharmacovigilance obligations of our Company. Pharmacovigilance is the scientific field of monitoring the safety of medicines and implementing procedures aimed at minimizing risk and improving therapeutic outcomes from their use. To achieve this, it is necessary to collect and manage drug safety data, detect risk signals, and assess the data. For more information on how to report suspected adverse drug reactions, please refer to the relevant “Pharmacovigilance” section of our Website available here.

When you submit a job application as a prospective employee or collaborator, either in response to a relevant job posting/announcement or unsolicited. In this case, we process your personal data in order to evaluate your application. For the processing of your personal data as a job applicant, please refer to the Candidate Privacy Policy on our Website available here.

When you subscribe to our newsletter via the relevant form on the Website. In this case, we process your personal data in order to send you the related content.

When you register as a physician to access the electronic services for viewing information on our pharmaceutical and parapharmaceutical products, through the relevant form on the Website. In this case, we process your personal data in order to create your electronic registration account and provide access to the relevant content. For your convenience, the registration form is also available here.

For simple browsing on our Website, we do not initially collect personal data. For more detailed information on the use of cookies, please refer to the Website’s Cookie Policy, which forms an integral part of the Privacy Policy and is available here.

If you choose not to provide your personal data in certain cases, we may not be able to respond to a particular request or inquiry.

2. Categories of personal data under processing

We may collect some of your personal data for communication purposes, such as to respond to your inquiries or requests for information. Specifically, when you use the Website’s contact form, we collect and process the information you directly provide, which may include: your name, email address, and the message you send to us. We will use this information to contact you and respond to your inquiry and/or request.

When, as a patient, healthcare professional, or third party, you submit a complaint or report regarding any alleged adverse reaction associated with CROSS’s pharmaceutical products, we collect and process personal data such as your full name, email address, information regarding the suspected adverse reaction, and potentially your professional capacity (e.g., in the case of a healthcare professional). We may also collect and process health-related personal data and medical history of the individual (e.g., patient) concerned by the complaint or report and who may have experienced the suspected adverse effects of the pharmaceutical product, if required for proper evaluation. We clarify that our Company, in order to fulfill its pharmacovigilance obligations under the legislation governing its pharmaceutical operations, must review and/or monitor any report it receives regarding alleged adverse reactions to its pharmaceutical products.

When you are a healthcare professional and we provide any benefit to you (such as donations, sponsorships, registration fees for conferences and scientific events for the medical community, as defined in the relevant circulars of the National Organization for Medicines – EOF) based on contract or voluntarily in relation to the promotion of prescription medicines, we collect and process specific personal data such as your full name, contact details, and information concerning the benefits and our contractual relationship.

We also collect and process specific categories of your personal data when you submit a job application to CROSS as a prospective employee, including your identification and contact details, information regarding your education and professional experience, and your CV. In this case, the Privacy Policy for Job Applicants specifically applies, which is available here.

When you subscribe to our newsletter by completing the relevant Website form, we collect and process your email address in order to send you the relevant material.

When you register for the Website’s electronic services as a physician, in order to create your online account and gain access to information regarding our pharmaceutical and para-pharmaceutical products (e.g., product leaflets), we collect and process data related to the creation of your account and your login details, such as your identification data (full name, username), contact information (email and/or phone number), details regarding your professional status (e.g., whether you are a private or hospital physician), and information regarding your actions through the account.

Data collected using cookies and other tracking technologies:

We also use cookies and collect information about how you use the Website, including technical data such as access time, volume of transmitted data, transmission status, browser type, version and language, browser plug-in type and version, IP address, operating system and system interface, time zone and location settings, and profile data, which includes referring websites, pages visited, actions taken, visit patterns, and website navigation.

Please refer to our Website’s Cookie Policy for further details, which is available here.

Data collected from third parties:

We receive some of the aforementioned technical data regarding your device (e.g., manufacturer, model, screen characteristics, operating system, etc.) or behavioral data (e.g., clicks, choices) from analytics providers such as Google.

Anonymized – statistical data:

We may process anonymized and statistical data for any purpose, especially for statistical reasons and to improve the Website’s services and information. Although such data may originate from your personal data, they are not considered personal if they do not directly or indirectly reveal your identity (e.g., we may aggregate website usage data to calculate the percentage of users accessing certain parts of the Website).

Special Categories of Personal Data – Health Data:

In order to review, evaluate, and monitor your report concerning any suspected adverse effects of one of our pharmaceutical products, we may process special categories of your personal data, such as your health data. These may include information about your medical history, known allergies to pharmaceutical products, or other medications or treatments you are following, when required.

3. Disclosure of Personal Data to Third Parties – Publication of Personal Data

As a general rule, we do not disclose or transfer personal data to third parties. However, CROSS may transfer data to third parties when such transfer is required by applicable legislation or, alternatively, in accordance with the safeguards provided by said legislation.

We do not share your personal data with third parties for the purpose of promoting products or services.

Service Providers

CROSS may appoint external/third-party service providers to offer support services to CROSS, including, for example, internet service providers or providers of technical and operational support for the Website, as well as pharmacovigilance service providers. In order for these support services to be provided, third-party providers may need to process your personal data. In such cases, they act as “data processors” under the GDPR and are required to process your personal data securely, act only on our instructions under the framework of our contractual relationship, and comply with the applicable data protection legislation.

Other Recipients

CROSS may disclose your personal data to judicial and/or prosecuting authorities, independent authorities, government bodies, or authorities competent for pharmacovigilance, in accordance with applicable personal data protection legislation. In the event of a merger or acquisition of CROSS by another organization, personal data may be transferred to third parties involved in the merger or acquisition (e.g., the acquiring organization, legal advisors, and auditors).

Transfers of Data Outside the European Union/European Economic Area

As a rule, we do not transfer your personal data outside the European Union (EU) or the European Economic Area (EEA). If, for the purposes outlined above, your personal data must be transferred outside the EU/EEA, such transfers will be made in accordance with applicable legislation. CROSS will ensure an adequate level of data protection, either through the execution of appropriate data transfer agreements based on Standard Contractual Clauses (available upon request at registration@crosspharma.gr), or by adopting other measures to guarantee an adequate level of protection of your personal data.

Disclosure of Personal Data Related to the Promotion of Medicinal Products

In accordance with applicable legislation, our Company, as a pharmaceutical entity, is obligated to publicly disclose, both on its own website and on the dedicated website of the National Organization for Medicines (EOF), no later than six months after the end of each calendar year, any benefit provided to third-party Healthcare Professionals and Scientific Healthcare Institutions. Such benefits include, but are not limited to, donations, sponsorships, registration fees for medical congresses and scientific events, travel and accommodation expenses, as well as any other provision granted under contract or voluntarily (e.g., donation, sponsorship), related to the promotion of prescription medicines. In fulfilling its legal obligations, our Company publishes the relevant information on our Website, which may include personal data of third parties (e.g., personal data of healthcare professionals). The information will remain publicly available on our Website for a maximum of three (3) years.

4. Legal Basis for Processing

We process your personal data when the law permits us to do so, that is, when we have a legal basis for the processing, specifically when:

– You have provided your consent for the processing of the data for one or more specific purposes (e.g. for the installation and use of certain optional types of cookies, when you subscribe to our newsletter, when you create an online registration account on the Website as a doctor to access product information material, when you contact us directly), in accordance with Article 6(1)(a) of the GDPR, as well as Article 9(2)(a) of the GDPR.

– The processing of your personal data is necessary for us to comply with our legal obligations, as well as to protect public health, as in the case of pharmacovigilance activities (see JMD DYG3a/GP 32221/2013), in accordance with Article 6(1)(c) of the GDPR, as well as Article 9(2)(i) of the GDPR. It should be noted that the processing act of disclosing the data of health professionals and any benefits our Company may provide to them for the promotion of prescription medicines is also necessary to comply with our legal obligations (see Article 66(7a) of Law 4316/2014), in accordance with Article 6(1)(c) of the GDPR.

– The processing of your personal data is necessary for the performance of our contract (e.g. in the case of sponsorship by our Company to a health professional), in accordance with Article 6(1)(b) of the GDPR.

– The processing is necessary for the purposes of the legitimate interests pursued by CROSS, provided that your fundamental rights do not override such interests, in accordance with Article 6(1)(f) of the GDPR. Such legitimate interests include: (a) monitoring to ensure the effective and secure operation of our Website and to prevent fraud and misuse, (b) optimizing our Website, (c) monitoring how our Website functions, e.g. through statistical data, in order to improve the design and information provided through our Website.

5. Retention period of personal data

Your personal data will be retained for as long as required to fulfill the purposes for which it may be collected, e.g., for as long as it is necessary to provide you with the functions of our website and the services you requested. Once the purpose for processing your personal data has been fulfilled, we will either delete your personal data or anonymize it, unless there are legal reasons requiring its retention. Specifically:

We retain your personal data collected when you contact us through our website or through any other available means of communication for the necessary time until the final resolution of the issue for which you contacted us (e.g., submission of a request or inquiry), and until any related claims are time-barred.

We retain your personal data collected in the context of a complaint or report regarding suspected adverse effects of the Company’s pharmaceutical products for as long as the pharmaceutical products are marketed and for at least 10 years after the expiration of their marketing authorization, or for a longer period if required by applicable (European and/or national) legislation.

We retain your personal data collected from you as a healthcare professional in case we provide you with benefits for the promotion of prescription drugs for as long as required during our contractual relationship and for as long as required by law after its termination, in order to fulfill our legal obligations (e.g., tax legislation) and until any related claims are time-barred.

We retain your personal data collected when you send us a job application following a job announcement until the position is filled. If you send a job application unsolicited (without a relevant announcement from us) and if we are not interested in a potential collaboration, your personal data is deleted one month after the date we received your application. In the event your application is rejected, if you request us to retain your application and related personal data (e.g., CV) in order to inform you about potential future job opportunities, we will retain your personal data for the period for which you have given your consent, or until you withdraw your consent before the end of that period. More detailed information can be found in the specific Privacy Policy for Job Applicants, available here.

We retain your personal data collected during your subscription to our newsletter (e.g., email address), for as long as you remain subscribed to our recipient list, and delete it upon withdrawal of your consent. Similarly, if you create an account as a physician on our Website to access informational materials (e.g., product information leaflets) related to our pharmaceutical and/or para-pharmaceutical products, we retain your personal data for as long as you remain an active user and until you withdraw your consent and delete your account.

Cookies are stored per session only, to assist your navigation on our website. “Persistent” cookies may be installed to save relevant preference parameters. For more information on how to control cookies, please refer to the chapter “How we use cookies and other tracking technologies” of this Website’s Cookie Policy available here.

6. Data security

Taking into account the latest developments, the cost of implementation, and the nature, scope, context, and purposes of the processing, as well as the risks of varying likelihood and severity to the rights and freedoms of natural persons arising from the processing, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risks of the processing.

7. Your rights

Under the conditions provided by the relevant legislation (GDPR), you have the following rights regarding the protection of your personal data:

Right of Access

You may contact CROSS to be informed and have explained whether and which data we hold about you, as well as how we process them. You may also request a copy of your personal data that CROSS holds about you.

Right to Rectification

If you believe your data is inaccurate or needs updating, you have the right to request the rectification of inaccurate personal data and the completion of incomplete information.

Right to Erasure

Under certain conditions, such as when the data is no longer necessary, you have withdrawn your consent, or the data has been unlawfully processed, you may request CROSS to delete them.

Right to Restriction of Processing

If you believe your data is inaccurate, the processing is unlawful, or you believe the data is no longer needed by CROSS, you have the right to request the restriction of processing.

Right to Object

You may object to the processing of your personal data by CROSS for reasons relating to your particular situation, unless there are compelling and legitimate reasons for the processing which override your interests, rights, and freedoms.

Right to Data Portability

You may request to receive your personal data in a structured, commonly used, and machine-readable format, as well as to have them transmitted to another organization (controller) designated by you to CROSS.

You can find more detailed information about your rights by visiting the website of the Hellenic Data Protection Authority here.

Right to Lodge a Complaint with the HDPA
We inform you that you have the right to lodge a complaint with the Hellenic Data Protection Authority (HDPA) regarding matters concerning the processing of your personal data. The HDPA is based in Athens (Kifisias 1-3, P.C. 115 23). For information on the authority’s responsibilities and how to file a complaint, please visit the HDPA’s website (www.dpa.gr).

Response Time for the Exercise of Your Rights

We are obliged to respond without delay and at the latest within one month from the time we receive your request to exercise any of the above rights. The one-month deadline may be extended by two months if the request is complex or if there is a large number of requests. In any case, we will inform you of any extension within one month of submitting your request. As a rule, your requests are submitted and fulfilled free of charge. CROSS may impose a reasonable fee in the case of a clearly unfounded or excessive request, especially due to its repetitive nature, or may refuse to fulfill the abusive request, in accordance with the applicable legislation. In the event your request is rejected, CROSS will inform you of the reasons for the rejection and your right to lodge a complaint with the Hellenic Data Protection Authority or to take legal action.

To exercise your rights, please contact CROSS in writing at the following email address:
registration@crosspharma.gr

8. Cookies Policy – How we use cookies and other tracking technologies

This Cookies Policy is an integral part of the Website’s Privacy Policy.

Our website uses cookies and therefore, when you visit it, a cookie may be installed on your device. A cookie is a small text file that may be loaded onto a “terminal device” (for example, your computer or mobile phone) when you browse the internet. It allows CROSS to recognize your device, gather information regarding usage patterns when you navigate our website, store some information about your preferences or past actions, and improve both the online experience and the personalized experience. Cookies may also be used to provide advertisements tailored to your interests on websites you visit and to analyze the effectiveness of those advertisements.

You can choose to allow or block cookies at any time – except for strictly necessary cookies (these are used to help make our website work effectively), you can delete cookies installed on your device at any time, prevent new cookies from being stored, and receive a notification before a new cookie is installed by configuring your browser software.

When specific types of cookies require your prior consent (e.g. advertising cookies) in order to be installed and used, you will be asked via a relevant banner upon entering the Website.

How can I change my cookie settings?

Most browsers allow some control over most cookies through their settings. To learn more about cookies, including how to see which cookies have been set, visit:
http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm,
or: www.aboutcookies.org
or: www.allaboutcookies.org

Learn how to manage cookies in popular browsers:

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