According to the provisions of the Regulation, the processing carried out by the Data Controller will be based on the principles of lawfulness, fairness, transparency, purpose and storage limitations, data minimisation, accuracy, integrity and confidentiality.
- Data Controller
- Personal data being processed
- Navigation data
- Special categories of personal data
- Data supplied voluntarily by the data subject
- Purposes of the processing
- Legal basis and the mandatory or optional nature of the processing
- Recipients of the personal data
- Transferring personal data
- Storing personal data
- Rights of the data subjects
1. Data Controller
The Data Controller for the processing carried out through the Website, is PDF S.r.l. as defined above, and may be contacted at: via Sant’Agnese 12, 20123 Milan (MI) – Italy – or at the e-mail address: email@example.com
2. Personal data being processed
Please be informed that following the browsing of the Website, the Data Controller will process your personal data which may consist of an identifier such as the name, an identification number, an online identifier or one or more factors specific to your physical, economic, cultural or social identity suitable to making the data subject identified or identifiable (hereinafter also, just, “Personal Data”).
The Personal Data processed through the Website is the following:
- Navigation data
During their ordinary operation, the computer systems and software procedures used to run the Website, collect some Personal Data whose transmission is inherent in the use of Internet communication protocols. This is not information that is collected to be associated with identified data subjects, but information that may, by its very nature, allow users to be identified after processing and association with data held by third parties. This category of data includes IP addresses or the domain names of computers used by users connecting to the Website, the URI (Uniform Resource Identifier) address notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the response file, the numerical code indicating the status of the server’s response (successful, error, etc.) and other parameters referred to the operating system and the user’s IT environment. This data is only used to obtain anonymous statistical information on the Website’s use and for the purposes of monitoring its correct functioning, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to establish liability in case of potential IT crimes against this Website or third parties.
- Special categories of personal data
In using some sections of the Website, a provision of your personal data that falls within the category of special categories of Personal Data as referred to in Article 9 of the Regulation may take place, verbatim the “[…] data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”. Should this be the case, please communicate such data only where necessary. In fact, we hereby remind you that in the face of transmissions of special categories of Personal Data, but in the absence of a specific indication of consent to process such data, PDF S.r.l. cannot, in any way, be held liable, nor would any claim to that effect be receivable, as in such case processing will be permitted as it would relate to data manifestly made public by the data subject in accordance with the requirements of Article 9.2.e) of the Regulation. In any event, should you wish to share the aforesaid data, we wish to specify, as already specified above, the importance of indicating your explicit consent to the processing of special categories of personal data.
- Data supplied voluntarily by the data subject
In using some Website services, the processing of third parties’ personal data which you have sent to PDF S.r.l. could take place. With respect to these instances, you are acting as an independent data controller, taking on all legal obligations and responsibilities. In this respect, you grant the most extensive indemnity with respect to any dispute, claim, request for damage compensation for processing, etc. that PDF S.r.l. should receive from third parties whose personal data have been processed through your use of the Website’s features in breach of the applicable regulations on personal data protection. In any event, should you provide or otherwise process Personal Data of third parties in using the Website, you warrant, as of now – taking on all related responsibilities – that such specific processing case is grounded on an appropriate legal basis pursuant to Article 6 of the Regulation which legitimizes the processing of such information.
The cookies that are on the Website are detailed at the following link: https://www.pharmadatafactory.com/en/cookie-policy
3. Purposes of the processing
The processing we intend to carry out is for the following purposes
- enabling the provision of the services you have requested;
- responding to requests for support or information;
- fulfilling potential legal, accounting and tax obligations
- protecting the interests and rights of PDF S.r.l. both in court and/or in out of court proceedings, also by carrying out checks on how the Website is being used, with the intent of preventing or detecting any abuse in the use of the Website, or any fraudulent activity.
4. Legal basis and the mandatory or optional nature of the processing
The legal basis for the processing of Personal Data for the purposes referred to in section 3 (a-b) is Article 6.1.b) of the Regulation as the processing is necessary for the provision of the services or in response to requests by the data subject. The provision of personal data for these purposes is optional, however failing to provide it would make it impossible to activate the services provided by the Website, or to respond to requests and/or the need for information.
The purpose referred to in section 3.c represents an essential processing of Personal Data pursuant to art. 6.1.c) of the Regulation. Once the personal data has been provided, the processing is indeed essential in order to comply with a legal obligation PDF S.r.l. is subject to.
The purpose referred to in section 3.d is based on the pursuit of a legitimate interest of PDF S.r.l., pursuant to Article 6.1.f) of the Regulation, i.e. to prevent and/or detect any fraudulent activity or abuse in the use of the Website, in addition to allowing PDF S.r.l. to protect its interests and rights both in court and/or in out of court proceedings.
Where necessary, specific summary information notices on the processing of Personal Data and requests for consent prepared for specific services will be gradually reported or displayed on the Website’s pages.
5. Recipients of the personal data
For the purposes referred to in section 3 above, your personal data may be shared with:
- individuals or entities who typically act as data processors pursuant to Article 28 of the Regulation, namely: i) people, companies or professional firms that provide assistance and advice to the Data Controller in accounting, administration, legal, tax and financial matters; ii) individuals or entities with whom an interaction is necessary for the provision of the Services (for example hosting providers); iii) or individuals or entities delegated to carry out technical maintenance activities (there including maintenance of network infrastructures and equipment as well as electronic communication networks); (collectively referred to as “Recipients”); the list of data processors who process data may be requested from the Data Controller by writing to the following address: firstname.lastname@example.org.
- independent subjects, body corporates or authorities, that are data controllers, to whom communicating your Personal Data is mandatory pursuant to legal provisions or requests by the authorities;
- people, authorized by PDF S.r.l to process Personal Data pursuant to Article 29 of the Regulation, as doing so is necessary in order to carry out activities strictly related to the provision of the Services, which have undertaken to respect the confidentiality or that are adequately legally bound to confidentiality (e.g. employees of PDF S.r.l.);
6. Transferring personal data
As for the potential transfer of Data to Third Countries, the Data Controller informs that the processing will take place in accordance with one of the methods permitted by the applicable law, such as: the adoption of Standard Clauses approved by the European Commission, and the selection of subjects, individuals or entities, adhering to international programs for the free circulation of data or operating in countries that the European Commission considers safe. More information is available, upon request, from the Data Controller at the above-indicated contact details.
7. Storing personal data
Personal Data processed for the purposes referred to in section 3 (a-b) will be stored for the time strictly necessary to provide the services offered on the Website in compliance with the principles of storage minimization and limitation pursuant to art. 5.1.e) of the Regulation. Personal Data processed for the purpose referred to in section 3.c, will be stored by PDF S.r.l. for the time specific legal obligations or applicable rules provide for.
The Personal Data processed for the purpose referred to in section 3.d, shall be stored by PDF S.r.l. for the time strictly necessary for the aforesaid purpose, therefore until such time as PDF S.r.l. shall be compelled to store them for legal protection purposes or to communicate the aforesaid data to the competent Authorities.
In any event, PDF S.r.l. shall process the Personal Data for the time necessary to fulfil contractual and legal obligations.
More information on the duration of data storage, and the criteria used to determine this period of time, may be requested from the Data Controller, in writing, at the e-mail address email@example.com.
8. Rights of the data subjects
Pursuant to Articles 15 et seq. of the Regulation, you have the right, at any time, to request access to your Personal Data, to request the rectification or erasure of the same, and request the restriction of processing of personal data for those cases provided for by Article 18 of the Regulation, and you have the right to obtain the data concerning yourself in a structured format, in a commonly used form that is readable by an automatic device for those cases provided for by Article 20 of the Regulation. At any given moment, and pursuant to Article 7 of the Regulation, you may withdraw your previously given consent and lodge a complaint with the competent supervisory authority under Article 77 of the Regulation, or file a claim before the Judicial Authority should you believe that the processing of your data breaches the currently applicable legal provisions.
You may lodge a request whereby you object to the processing of your data pursuant to Article 21 of the Regulation, and in which you substantiate the reasons and grounds for the objection: the Data Controller reserves the right to assess the application, which would not be accepted should there be compelling legitimate grounds for the processing which override your interests, rights and freedoms.
Requests should be sent in writing to the Data Controller at the e-mail address: firstname.lastname@example.org.
Last updated: 25 Sept. 2023