Privacy policy

Valid from: 23.05.2018

We are very pleased that you are interested in our company. Data protection has a particularly high priority for the management of sanPharma GmbH. Use of the sanPharma GmbH website is basically possible without providing any personal data. If a data subject wishes to use our company's special services via our website, processing of personal data may be necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, for example the name, address, email address or telephone number of a data subject, always takes place in accordance with the General Data Protection Regulation and in accordance with the country-specific data protection regulations applicable to sanPharma GmbH. With this data protection declaration, our company would like to inform the public about the type, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed about their rights by means of this data protection declaration.

As the controller, sanPharma GmbH has implemented numerous technical and organizational measures to ensure the most complete protection possible for the personal data processed via this website. Nevertheless, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us in alternative ways, for example by telephone.

1. Definitions

The data protection declaration of sanPharma GmbH is based on the terminology used by the European directives and regulations when issuing the General Data Protection Regulation (GDPR). Our data protection declaration should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

In this data protection declaration, we use, inter alia, the following terms:

  • a) Personal data
    Personal data is all information that relates to an identified or identifiable natural person (hereinafter "data subject"). An identifiable person is a natural person who, directly or indirectly, in particular by assigning an identifier such as a name, an identification number, location data, an online identifier or one or more special characteristics, expresses the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person can be identified.
  • b) Data subject
    Affected person is any identified or identifiable natural person whose personal data are processed by the controller.
  • c) Processing
    Processing is any process or series of processes carried out with or without the help of automated processes in connection with personal data such as the collection, recording, organization, ordering, storage, adaptation or modification, reading, querying, use, the disclosure by transmission, distribution or any other form of provision, comparison or linking, restriction, deletion or destruction.
  • d) Restriction of processing
    Restriction of processing is the marking of stored personal data with the aim of restricting their future processing.
  • e) Profiling
    Profiling is any type of automated processing of personal data, which consists in the fact that this personal data is used to evaluate certain personal aspects that relate to a natural person, in particular aspects related to work performance, economic situation, health, personal Analyze or predict the preferences, interests, reliability, behavior, location or change of location of this natural person.
  • f) Pseudonymization
    Pseudonymization is the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organizational measures that ensure that the personal data cannot be assigned to an identified or identifiable natural person.
  • g) Responsible or for processing
    The person responsible or responsible for processing is the natural or legal person, public authority, agency or other body that alone or together with others decides on the purposes and means of processing personal data. If the purposes and means of this processing are specified by Union law or the law of the Member States, the person responsible or the specific criteria for naming them can be provided in accordance with Union law or the law of the Member States.
  • h) Processors
    The processor is a natural or legal person, public authority, agency or other body that processes personal data on behalf of the person responsible.
  • i) Recipient
    The recipient is a natural or legal person, public authority, agency or other body to which personal data is disclosed, regardless of whether it is a third party or not. However, authorities that may receive personal data as part of a specific investigation mandate under Union law or the law of the Member States are not considered recipients.
  • j) Third party
    A third party is a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons who are authorized to process the personal data under the direct responsibility of the controller or processor.
  • k) Consent
    Consent is any expression of will voluntarily given by the data subject for the specific case in an informed manner and unequivocally in the form of a declaration or other clear confirmatory act, with which the data subject indicates that they consent to the processing of their personal data is.

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

sanPharma GmbH
Brandshofer Deich 10
20539 Hamburg, Germany

Phone: +49 40 228 58 56 0
Email: info[a]sanpharma.com
Website: www.sanpharma.com

3. Cookies

The sanPharma GmbH website uses cookies. Cookies are text files that are stored and stored on a computer system via an internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the dats subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

By using cookies, sanPharma GmbH can provide users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

4. Collection of general data and information

The website of sanPharma GmbH collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the log files of the server. The following can be recorded: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites that use an accessing system on our website can be controlled, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system and (8) other similar data and information that serves to avert risks in the event of attacks on our information technology systems.

When using this general data and information, sanPharma GmbH does not draw any conclusions about the person concerned. Rather, this information is required to (1) correctly deliver the content of our website, (2) optimize the content of our website and the advertising for it, (3) to ensure the long-term functionality of our information technology systems and the technology of our website, and ( 4) to provide law enforcement authorities with the information necessary for law enforcement in the event of a cyber attack. This anonymously collected data and information is therefore statistically evaluated by sanPharma GmbH and also with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

5. Registration on our website

The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.

By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons

6. Subscription to our newsletters

On the website of sanPharma GmbH, users are given the opportunity to subscribe to our company's newsletter. Which personal data are transmitted to the person responsible for processing when you order the newsletter is determined from the input mask used for this purpose.

sanPharma GmbH informs its customers and business partners at regular intervals by means of a newsletter about offers of the company. The newsletter of our company can only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject registers for the newsletter. For legal reasons, a confirmation email will be sent to the e-mail address entered by the data subject for the first time for sending the newsletter in a double opt-in procedure. This confirmation email is used to check whether the owner of the email address as the person concerned has authorized the receipt of the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.

7. Newsletter tracking

The sanPharma GmbH newsletters contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in emails that are sent in HTML format in order to enable log file recording and log file analysis. This enables a statistical evaluation of the success or failure of online marketing campaigns to be carried out. Based on the embedded tracking pixel, sanPharma GmbH can recognize whether and when an email was opened by a data subject and which links in the email were called up by the data subject.

Such personal data collected via the tracking pixels contained in the newsletters are stored and evaluated by the data controller in order to optimize the sending of the newsletter and to adapt the content of future newsletters even better to the interests of the person concerned. This personal data will not be passed on to third parties. Affected persons are entitled at any time to revoke the separate declaration of consent relating to this, which is made using the double opt-in procedure. After revocation, this personal data will be deleted by the controller. Unsubscribing from receiving the newsletter automatically interprets sanPharma GmbH as a revocation.

8. Contact possibility via the website

Due to legal regulations, the website of sanPharma GmbH contains information that enables quick electronic contact to our company as well as direct communication with us, which also includes a general address for the so-called electronic mail (email address). If a data subject contacts the data controller by email or via a contact form, the personal data transmitted by the data subject will be automatically saved. Such personal data transmitted by a data subject to the data controller on a voluntary basis are stored for the purpose of processing or contacting the data subject. This personal data is not passed on to third parties.

9. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

10. Rights of the data subject

  • a) Right to confirmation
    Every data subject has the right granted by the European directive and regulation giver to ask the data controller to confirm whether personal data relating to them are being processed. If a data subject wishes to exercise this right of confirmation, they can contact an employee of the controller at any time.
  • b) Right to information
    Any person affected by the processing of personal data has the right granted by the European directive and regulation giver to receive free of charge information about the personal data stored about him and a copy of this information from the controller at any time. In addition, the European directive and regulation giver has granted the data subject information about the following information:
    • the purposes of the processing;
    • the categories of personal data concerned;
    • he recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
    • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
    • the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
    • the existence of the right to lodge a complaint with a supervisory authority;
    • where the personal data are not collected from the data subject, any available information as to their source;
    • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject. Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
  • c) Right to rectification
    Any person affected by the processing of personal data has the right granted by the European directive and regulation giver to request the immediate correction of incorrect personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data, also by means of a supplementary statement, taking into account the purposes of the processing. If a data subject wishes to exercise this right of correction, they can contact an employee of the controller at any time.
  • d) Right to erasure (right to be forgotten)
    Any person affected by the processing of personal data has the right granted by the European directive and regulation giver to demand from the responsible person that the personal data concerning them be deleted immediately if one of the following reasons applies and if the processing is not necessary:
    • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
    • The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
    • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
    • The personal data have been unlawfully processed.
    • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
    • The personal data was collected in relation to information society services offered in accordance with Art. 8 Para. 1 GDPR.
    • If one of the above reasons applies and a data subject wishes to have personal data stored by sanPharma GmbH deleted, they can contact an employee of the controller at any time. The employee of sanPharma GmbH will arrange for the request for deletion to be complied with immediately.
    • If the personal data has been made public by sanPharma GmbH and our company is responsible as a responsible person pursuant to Art. 17 Para. 1 GDPR to delete the personal data, sanPharma GmbH will take appropriate measures, taking into account the available technology and the implementation costs, too of a technical nature, in order to inform other data controllers who process the published personal data that the data subject has deleted from them all other data controllers the deletion of all links to this personal data or copies or replications of this personal data has requested, as far as the processing is not necessary. The employee of sanPharma GmbH will arrange the necessary in individual cases.
  • e) Right to restriction of processing
    Any person affected by the processing of personal data has the right granted by the European directive and regulation giver to request the controller to restrict processing if one of the following conditions is met:
    • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
    • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
    • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
    • The data subject has objected to processing in accordance with Art. 21 para. 1 GDPR and it is not yet clear whether the legitimate reasons of the person responsible outweigh those of the data subject. If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by sanPharma GmbH, they can contact an employee of the controller at any time. The employee of sanPharma GmbH will arrange for the processing to be restricted.
  • f) Right to data portability
    Every person affected by the processing of personal data has the right granted by the European directive and regulation giver to receive the personal data concerning them, which were provided by the data subject to a responsible person, in a structured, common and machine-readable format. You also have the right to transfer this data to another controller without hindrance from the controller to whom the personal data has been provided, provided that the processing is based on consent in accordance with Art. 6 Para. 1 Letter a GDPR or Art. 9 Para . 2 letter a GDPR or on a contract pursuant to Art. 6 para. 1 letter b GDPR and the processing is carried out using automated processes, unless the processing is necessary for the performance of a task that is in the public interest or in the exercise of official authority, which has been transferred to the person responsible Furthermore, when exercising their right to data portability in accordance with Art. 20 Para. 1 GDPR, the data subject has the right to have the personal data transferred directly from one person responsible to another, insofar as this is technically feasible and if so this does not affect the rights and freedoms of other people. In order to assert the right to data portability, the data subject can contact an employee of sanPharma GmbH at any time.
  • g) Right to object
    Any person affected by the processing of personal data has the right granted by the European directive and regulation giver, for reasons arising from their particular situation, at any time against the processing of personal data concerning them, which is based on Art. 6 Para. 1 Letter e or f DS-GVO takes place to object. This also applies to profiling based on these provisions. In the event of an objection, sanPharma GmbH will no longer process the personal data, unless we can demonstrate compelling legitimate grounds for the processing that outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend of legal claims. If sanPharma GmbH processes personal data in order to operate direct mail, the person concerned has the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling insofar as it is connected to such direct advertising. If the data subject objects to sanPharma GmbH processing for direct marketing purposes, sanPharma GmbH will no longer process the personal data for these purposes. In addition, the person concerned has the right, for reasons arising from their particular situation, against the processing of personal data relating to them, which is carried out at sanPharma GmbH for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 Para. 1 DS- GMOs are subject to objection, unless such processing is necessary to fulfill a task in the public interest. To exercise the right to object, the data subject can directly contact any employee of sanPharma GmbH or another employee. The data subject is also free to exercise their right to object in connection with the use of information society services, regardless of Directive 2002/58 / EC, using automated procedures that use technical specifications.
  • h) Automated decisions in individual cases including profiling
    Any person affected by the processing of personal data has the right granted by the European directive and regulatory authority not to be subjected to a decision based solely on automated processing - including profiling - which has legal effects or similarly significantly affects them, if the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is permissible on the basis of Union or Member State law to which the controller is subject and this legislation takes appropriate measures to protect the rights and freedoms as well as the legitimate interests of the data subject or (3) with the express consent of the data subject. If the decision (1) is necessary for the conclusion or fulfillment of a contract between the data subject and the person responsible or (2) it is made with the express consent of the data subject, sanPharma GmbH takes appropriate measures to protect the rights and freedoms as well as the justified ones Protect the interests of the data subject, which includes at least the right to obtain the intervention of a person on the part of the person responsible, to state their own position and to contest the decision. If the data subject wishes to assert rights with regard to automated decisions, they can contact an employee of the controller at any time.
  • i) Right to withdraw consent under data protection law
    Any person affected by the processing of personal data has the right granted by the European directive and regulation giver to revoke their consent to the processing of personal data at any time. If the data subject wishes to exercise their right to withdraw consent, they can contact an employee of the controller at any time.

11. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR.

In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR.

Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

12. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

13. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

14. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner).

Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded.

Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

15. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.

This Privacy Policy has been generated by the Privacy Policy Generator of the DGD - Your External DPO that was developed in cooperation with German Lawyers from WILDE BEUGER SOLMECKE, Cologne.

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