This Policy contains the information required by art. 13 of Regulation (EU) 679/2016, concerning the protection of natural persons with regard to the processing of Personal Data (hereinafter “GDPR“). This document has therefore been produced to provide you with information on the purpose and means used to process your Personal Data which are collected when browsing on our website (https://summitpharmaeurope.com/ – hereinafter referred to as the “Website”), or when you fill out our contact forms to request information about our services, or to participate to our events.
We inform you that the processing of Personal Data (name, surname, telephone, email address and any further Personal Data indicated in the request of information) (the “Data”) that you spontaneously provided to us will respect the principles of fairness, lawfulness and transparency and protection of your privacy and your rights.
You may access the Website without the need to provide any Data. However, the information systems used to manage the Website will, during their normal operations, acquire some Personal Data, the transmission of which is considered as implied in the use of Internet communication protocols. These data are not collected with a view to being associated with identified data subjects, but given their nature they may, through processing and association procedures, allow the individuals who navigate through the Website to be identified.
This category includes, for example, the IP addresses of the computers that connect to the Website, the URL of the requested resources and the time of the request.
We only use technical cookie. No user profiling cookies are used. The only processing operation we perform is related to the creation of statistics via pseudonymised data concerning navigation on the Website.
- Data Controller
The Data Controller of Personal Data is Summit Pharmaceuticals Europe S.r.l., with legal office in Milan, Viale Piero ed Alberto Pirelli, in person of its legal representative pro tempore (hereinafter “SPE” or “us” or “Data Controller”), that can be reached at the email spe-privacy@sumitomocorp.com.
SPE is the Data Controller pursuant to article 4, n. 7) of GDPR and, as such, is responsible for the legitimate and correct processing of your Data.
- The purposes of Personal Data Processing
The Data provided by you by filling the contact form on the Website will be processed by us in respect of the modalities provided by the GDPR for the following purposes:
- to process your requests of information and/or contacts and to respond to such requests, also by sending communications and details relating to the above;
- to allow you to register and participate any of our events that you wish to attend;
- with your prior express consent, to send to you, by email, newsletters having informative / advertising nature, commercial communications and invitations to events organized by SPE or by the companies of the Sumitomo Corporation Group.
- Data recipients – Transfer of Data to Third Countries or International Organizations
In order to process your request for information and/or contact and only if this is deemed as necessary from the content of the same, your Data may be communicated to other entities of the Sumitomo Corporation Group if directly interested by your request. Said other companies of the Sumitomo Corporation Group will process your Data as an independent Data Controller.
In some cases, the personal data we collect from you might be processed outside the European Economic Area (“EEA”), such as the United States and the countries in which the companies of the Sumitomo Corporation Group operate. In such a case, SPE warrants that the Data will only be transferred to countries which provide a level of protection adequate to the one set out by the EU applicable legal framework, or by means of the implementation of adequate safeguards to protect your Data, such as the Standard Contractual Clauses issued by the Eu Commission with the implementing decision (UE) 2021/914 of June 4th 2021.
The aforementioned Data shall not be disclosed to undetermined subjects. For further information regarding the countries to which your Data may be transferred, please contact us by email at spe-privacy@sumitomocorp.com.
Your Data will also be made accessible to third parties who perform maintenance and technical assistance activity on the IT systems used for the processing and storage of Data, which also include companies of the Sumitomo Corporation Group; these companies will be appointed by us as Data Processors. The updated list of Data Processors will be made available upon request to the Data Controller to be sent by email to the following address spe-privacy@sumitomocorp.com.
- Data Processing Arrangements – Data retention time.
Your Data will be processed using both paper and electronic means.
Your Personal Data will be stored by adopting technical and organizational security measures appropriate to ensure their protection, for the period of time strictly necessary to execute your request for information and / or contact, and to allow the participation to the event you have registered for. For the purpose referred to in point 2 c) above, we will store your data for a period of time equal to twenty-four months from the date of their registration in our database. In any case, once the maximum data retention period has elapsed, they will be automatically deleted or rendered anonymous.
Your Data will not be used for profiling purposes.
- Mandatory or optional nature of providing of Data – Consequences of the possible refusal.
The provision of Data for the purposes referred to in paragraph 2 a) and b) above is mandatory as necessary to enable us to process your requests.
The provision of Data for the purposes referred to in paragraph 2 c) above is optional; consequently, without your explicit consent, we will not process the Data for advertising and marketing purposes indicated therein. You have the right to freely object at any time to the processing of your personal data for marketing purposes. If you change your mind about being contacted for marketing purposes in the future, please select “unsubscribe” from our messages if you do not want to receive further marketing emails, or contact us by email at spe-privacy@sumitomocorp.com.
- Data Subject’s rights
As a data subject, You have the right to exercise at any time, the following rights set forth in Articles 15 to 22 of the GDPR, including (i) the right of access to personal data (i.e., the right to obtain from us confirmation as to whether or not we are processing data relating to you and, if so, to obtain access to the personal data, obtaining a copy thereof, and to the information referred to in Art. 15 of the GDPR), (ii) the rectification (i.e., the right to obtain the rectification of inaccurate data concerning him/her or the supplementation of incomplete data) or the deletion of the same, if one of the reasons indicated in Art. 17 of the GDPR, or the restriction of the processing concerning you (i.e., the right to obtain, in the cases indicated by Art. 18 of the GDPR, the marking of the data stored with the aim of limiting their processing in the future), (iii) the right to data portability (i.e., the right, in the cases indicated by Art. 20 of the GDPR, to receive from us, in a structured, commonly used and machine-readable format, data concerning you, as well as to transmit such data to another data controller without impediment). You have, in addition, the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you pursuant to Article 6(1) (e) performance of a task carried out in the public interest or in the exercise of official authority) or (f) (legitimate interest) of the GDPR, including profiling on the basis of these provisions. You also have the right to withdraw your consent at any time when a processing is based on your consent. Revocation of consent does not affect the lawfulness of processing based on consent prior to revocation.
The exercise of such rights is not subject to any form constraint and is free of charge. For this purpose, you may contact the Data Controller by sending a registered letter to the address in point 1 above, or by e-mail using the following address: spe-privacy@sumitomocorp.com.
We remind you that you always have the option of lodging a complaint with the Data Protection Authority (www.garanteprivacy.it) or the different Supervisory Authority of the EU Member State where you reside or work or where the alleged violation occurred.
- Changes to the privacy policy
This privacy policy may be subject to changes and/or updates. Any changes will, in any case, ensure that your rights are fully protected. If any changes are made that may limit the safeguards protecting your data or your rights compared to the current version, you will be promptly notified before the processing of your data begins under the new terms. In any case, we encourage you to consult this policy regularly so that you remain up-to-date with respect to any changes that have occurred since your last consultation.