Privacy Policy
Welcome to the Privacy Policy of LABORATORIOS CINFA S.A. (hereinafter, “CINFA”). In this document, you will find information of interest to you about how CINFA processes your personal data and the rights that protect you under the General Data Protection Regulation (GDPR) and the Spanish Constitutional Law on Data Protection and the Guarantee of Digital Rights (LOPD).
Identification and Contact Details of the Data Controller.
CINFA is an internationally operating Spanish company that is engaged in the pharmaceutical and health sector, the main headquarters of which is located in Navarre, Spain.
You can contact CINFA through the following channels:
- In person or via post addressed to LABORATORIOS CINFA S.A. at Travesía de Roncesvalles, Nº 1, Polígono de Olloki 31699 Olloki (Navarre), Spain
- By e-mail to: lopd@cinfa.com
- By calling the customer service helpline: 948 33 38 11
Exercising your Rights
We inform you of your entitlement to exercise the following rights:
- Right of access to your personal data to know which are being processed and the processing activity being applied to them;
- Right of rectification regarding any inaccurate piece of personal data;
- Right of erasure regarding your personal data, when this is possible;
- Right to request restricted processing of your personal data when the accuracy, legality or need to process the data may be questionable, in which case we may only keep the data for the purpose of exercising a defence against legal complaints;
- Right of opposition to the processing of your personal data, when the legal grounds that entitle us to process the same is a legitimate interest. CINFA will stop processing your data unless it has an overriding legitimate interest or to lodge, exercise or defend against legal complaints.
- Right of portability regarding your data, when the legal grounds that entitle us to process the same is the existence of a contractual relationship or your consent.
- Right to withdraw the consent given to CINFA.
Furthermore, we inform you of your entitlement to lodge a complaint with the Spanish Data Protection Agency if you believe that data protection regulations have been breached with regard to the processing of your personal data.
Information about the Data Processing carried out by CINFA
CINFA has a Processing Activities Log listing all the processing activities carried out as data controller.
| PROCESS | PURPOSE | LEGAL GROUNDS |
| CALL CENTRE | Response to queries, complaints and claims from customers and the general public regarding the products and services from CINFA. | Consent Legitimate interest |
| REPORTING CHANNEL | Managing the details of whistle-blowers, reported individuals and witnesses within the internal information system via which reports on conduct, actions or facts in breach of regulations of the CINFA GROUP code of conduct are channelled. | Legal compliance |
| CONSUMERS | Managing the customers and users of products and services that CINFA offers to pharmacies (product experiences). | Consent |
| MARKETING CAMPAIGNS | Conducting promotional campaigns about pharmaceutical products and services in the installations of the offices of client pharmacists of CINFA. Conducting campaigns of a general nature about the CINFA brand, satisfaction surveys, etc. Organising events, promotions, training, prize draws, etc. aimed at pharmacists and other customers, healthcare professionals, employees of pharmacy offices, partners and people interested in the products from CINFA. | Consent Legitimate interest Spanish Law on Services of the Information Society |
| CUSTOMERS | Administrative and accounting management of customer pharmacies. Managing the services that CINFA provides to pharmacies, which includes the relationship between the latter and direct consumers. | Contractual relationship Compliance with legal obligations |
| PHARMACOVIGILANCE | Identification, quantification, assessment and prevention of possible risks stemming from the use of CINFA products, including medicines, healthcare products, cosmetics, nutritional supplements and pesticides. | Legal compliance |
| TRAINING | Training for healthcare professionals. Training for pharmacy owners and their employees. | Consent |
| STAFF MANAGEMENT | Hiring and managing the payroll of all personnel (including tax management). Management and administration of CINFA employees regarding compliance with the Workers’ Statute and the collective bargaining agreement on matters related to salary, working hours, timetable control, attendance control, disciplinary system, negotiation of the collective bargaining agreement, works committee, personal and professional development, ongoing training and specific training on occupational risk prevention. | Contract Compliance with employment obligations Legitimate interest |
| USE OF IMAGES | Use of images used for publication in the “Who’s Who” corporate tool, as well as corporate presentations and brochures sent by digital and/or conventional means. Capture and use of images of employee relatives for non-promotional purposes. | Legitimate interest / Consent |
| JOURNALISTS | Contact with the media. | Legitimate interest |
| EXTERNAL PERSONNEL AND SUBCONTRACTORS | Coordination of business activities in accordance with employment and occupational risk prevention legislation. | Legal compliance |
| CONTACT PERSONS | Management of contact persons at service providers and suppliers of CINFA. Management of contact persons who are interested in managing partnership projects with CINFA. | Legitimate interest Contract / Application of pre-contractual |
| VISITORS LOG | Access control and keeping a record of visits to CINFA premises for security reasons. | Legitimate interest |
| PERSONNEL SELECTION | Management of CVs for recruitment processes and automatic job applications. | Consent |
| VIDEO SURVEILLANCE | Recording images of the perimeter of the premises, as well as such common installations as indoor building corridors, for security purposes. Production chain control. | Legitimate interest |
| USER MANAGEMENT OF THE CINFA COMMUNITY | Management of contact registration in the CINFA Community. | Consent |
| CLINICAL TRIALS AND OTHER CLINICAL AND PHARMACOVIGILANCE STUDIES | Management as sponsor of clinical trials and epidemiological, observational, bioequivalence, and post-authorization safety studies (which may be clinical or observational). | Public interest and purposes of archiving in the public interest, scientific or historical research purposes, or statistical purposes in relation to compliance with legal obligations. |
Security Measures
We apply all the necessary security measures of a technical and organisational nature to prevent the alteration, loss, processing or unauthorised access to the information based on the state of the art, the nature, scope, context and purpose of the processing activity, and the risks to which they are exposed, whether they stem from human action or the physical or natural environment.
How long will we keep your data?
For each processing activity, the data will be kept for as long as the established relationships persist and, subsequently, for the applicable legal periods and the time necessary to achieve the purpose for which they were collected and to determine any possible liabilities that may stem from said purpose and from processing the data. Only the data strictly necessary for each processing activity are requested.
Recipients
Your personal data may be shared with businesses that form part of the company or the Group under Recital 48 of the GDPR and while guaranteeing the purpose for which said data were collected is maintained. Beyond these circumstances, your data will not be shared with third parties unless legally required to do so.
Transfer of your Data
In the event of publication of the data in photos or videos on the YouTube portal or on such social media as Facebook, Instagram or Twitter, an international transfer thereof will take place to Google, Inc., Facebook, Inc., Instagram and Twitter, Inc., respectively, entities located in the United States, based on an adequacy finding as a country with guarantees of an adequate level of protection or, in the absence of an adequacy finding, in accordance with the express consent of the data subject. For more information, please see the privacy policy of said entities.
Confidentiality
The personal data that we may gather via the website or the various communications we maintain with you will be processed confidentially, and we undertake to maintain the confidentiality of the same in accordance with the provisions of applicable legislation.
Changes to the Privacy Policy
It may be the case that this Privacy Policy must be updated. We therefore recommend that you review this policy on a regular basis and, if possible, every time you access the website in order to be duly informed about the data collection and data processing actions undertaken. The Privacy Policy can be found at the bottom of the website.
