PRIVACY POLICY

This privacy policy (the “Privacy Policy”) sets out the rules and procedures as to the processing of personal data (i.e. data by which you may be directly or indirectly identified, hereafter the Personal Data) in accordance with the Data Protection Legislation when accessing and browsing the website https://pharmatainer.cellon.lu/ (the Website).

Data Protection Legislation means the General Data Protection Regulation (EU) 2017/69 of the European Parliament and of the Council of 27 April 2016 (the GDPR), as well as any other applicable laws, regulations and sector recommendations containing rules for the protection of individuals with regard to the processing of Personal Data.

Who is the data controller and who to contact?

Any Personal Data provided to or collected by us will be processed (i.e. used, stored, transmitted, etc.) in accordance with this Privacy Policy by us, Cellon S.A., having our registered office at 16, rue Héierchen L4940 Bascharage, Luxembourg, and registered with the Trade and Companies Register of Luxembourg under number B25789 (hereafter “Cellon” “we” or “us”), in our capacity as controller or by our subcontractors and service providers as further described in this Privacy Policy in their capacity as processors.

Should you have any requests concerning your Personal Data, you can contact Cellon at privacy@cellon.lu.

What personal data IS PROCESSED?

Cellon receives and collects the Personal Data directly from you or through the use of automated technology when you use and interact with the Website. In particular, the Personal Data Cellon processes about you may include:

  • personal data that you provide to us when filling in forms on the Website or using the contact details displayed on the Website (this includes your first name, last name, company or organization for which you work, function or title within a company or organization, country, email address, business address, telephone number, and any other information you include in your communication with us).
  • data technically transmitted when you access or browse the Website, such as your IP address and data obtained through the use of cookies or similar technologies (including date and time of access, operating system used, number of visits, pages of the Website you have visited, etc.). Please also refer to clause 4 “Cookies” and to the Cookie Policy for further information on Personal Data gathered through the use of cookies.

For which purposes does Cellon process personal data and on which legal basis?

Based on Cellon’s or a third party’s legitimate interest

We process your Personal Data in our interests or to pursue third party’s legitimate interests. These interests cover processing to:

  • identify you and to enable us to properly answer your query;
  • keep a record of your relationship with us;
  • improve the performance and usability of the Website;
  • send updates and announcements about Cellon products and services;
  • establish statistics and the conduct of Website trends, performance and commercial analysis;
  • assure the safety and continuity of Cellon’s IT services and systems;
  • prevent and detect fraud;
  • establish, exercise and defend legal claims; and
  • in connection with any business reorganisation, transfer, disposal, merger or acquisition on the level of Cellon.

With your consent

Insofar as you have given Cellon your consent for the processing of your Personal Data, such consent will serve as a legal basis for the referred processing.

This includes the consent you may have given in relation to the use of cookies or the possibility to be contacted in relation of commercial communication on our events and information about our activities, products and services, as well as to receive Cellon’s newsletter.

Cookies

A “cookie” is a small piece of code that a website places in the cookie file of your browser and that allows the website to remember who you are.

Like many other website, Cellon uses cookies or similar technologies (like page tags) to provide you with a safe, effective and user friendly Website. Cellon also uses cookies to compile certain information to determine visitor’s preferences and trends in relation to the web browsing activity.

You have the choice of deciding whether to accept cookies or not by exercising such choice in the cookie banner available on the Website or by setting your browser to block some or all cookies. However, please be aware that if you do not accept cookies, you may not be able to enjoy a comprehensive experience of the Website features. Cookies that are necessary for the functioning of the Website cannot be refused.

For more information on the use of cookies, please refer to Cellon’s Cookie Policy.

Who receives your personal Data?

The following recipients may receive your Personal Data:

  • service providers, including but not limited to IT or website services suppliers and archiving storage providers, that process your Personal Data on Cellon’s instructions;
  • government, courts, law enforcement authorities, regulators or attorneys and supervisory authorities;
  • parties involved in the context of a company restructuring, transfer, divestiture, merger or acquisition impacting Cellon;
  • shareholders, agents, employees, consultants, representatives, auditors and business partners; and
  • other companies belonging to the same group as Cellon (and if necessary, their respective shareholders, agents, employees, consultants, representatives, auditors, service providers and business providers).

Where is your personal data transferred to?

For the purposes listed above, your Personal Data may be transferred to any of the aforementioned recipients and service providers in countries located in or outside of the European Economic Area (the EEA).

Your Personal Data may be transferred to the following countries located outside of the EEA: the United States of America.

Personal Data transferred to countries outside of the EEA will be protected by appropriate safeguards such as standard contractual clauses approved by the European Commission. You may obtain a copy of such safeguards by contacting Cellon at its registered office (see clause 1 above) or at privacy@cellon.lu.

How long does Cellon retain your personal data?

The retention periods for your Personal Data are based on Cellon’s business needs and legal requirements.

Cellon may notably retain:

  • Personal Data you have submitted to Cellon through a specific request until we have responded to your request or until the end of the exchange relating thereto, plus ten (10) years as of the end of such communication; and
  • cookies for a maximum of six (6) months after your last use of the Website.

Cellon may also retain your Personal Data other than related to cookies for up to two (2) years for statistics, business analysis and marketing purposes.

Do you have the obligation to provide Personal Data?

In the context of Cellon’s business and the functioning of the Website, you only have to provide the Personal Data that is necessary for Cellon to reply to your requests, or for the Website to run properly.

However, please be aware that without certain types of Personal Data (notably Personal Data relating to cookies that are necessary to be able to browse the Website), Cellon will not be able to duly reply to your requests or some parts of the Website may become inaccessible.

To what extent DOES Cellon use automated decisions making or profiling?

In general, Cellon does not use automated individual decision-making or profiling in the course of the relationship with you. Should Cellon rely on such processing, Cellon would inform you separately.

What are the rights of the users?

The exercise of the below rights is free of charge and not bound to any formalities. You may exercise these rights by contacting us through the contact information included in clause 1 above.

To protect your privacy and security, Cellon may takes steps to verify your identify before complying with any of your requests.

Right to information, rectification, erasure and restriction of processing

You may request to obtain, within reasonable intervals, and in a timely manner, the communication of your Personal Data that is being processed by Cellon, as well as all information on the origin of those Personal Data.

You also have the right to rectify Personal Data that is inaccurate.

In cases where the accuracy of the Personal Data is contested, the processing is unlawful, or where you have objected to the processing of your Personal Data, you may ask for the restriction of the processing of such Personal Data. This means that Personal Data will, with the exception of storage, only be processed for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of an EU Member State. In case a processing is restricted, you will be informed before the restriction of processing is lifted.

You may request the deletion of Personal Data, without undue delay when the use or other processing of such Personal Data is no longer necessary for the purposes described in clause 3 above, and notably when consent relating to a specific processing has been withdrawn or where the processing is not or no longer lawful for other reasons.

Right to object

You may object to the processing of your Personal Data which is based on the legitimate interests pursued by Cellon or by a third party. In such a case Cellon will no longer process your Personal Data unless Cellon or the third party has compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Right to withdraw consent

You have the right to withdraw your consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal. The withdrawal only affects future processing.

A possibility to unsubscribe from the electronic Cellon newsletter is provided by default in form of an “Unsubscribe” link at the end of each newsletter.

Right to data portability

Where the processing of your Personal Data is based on consent or the execution of a contract with you, you also have the right to data portability for information you provided to Cellon– this means that you can obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and potentially transmit it to another controller.

Right to lodge a complaint

In the event that you wish to complain about how Cellon processes your Personal Data, and/or if you want more details on the processing of your Personal Data and/or if you have any specific queries or concerns regarding the processing of your Personal Data, please contact Cellon in the first instance using the contact details provided in clause 12 and Cellon will endeavour to deal with your request as soon as possible.

This is without prejudice to your right to file a complaint with the Luxembourg data protection authority, the Commission nationale pour la protection des données, or any other competent data protection authority (e.g. that of your country of residence), in the event you have concerns on the processing of your Personal Data.

Links to third party websites

The Website might contain link to third party websites (e.g. Linkedin, Twitter, etc.).

This Privacy Policy solely concerns the Website, and Cellon’s processing of personal data.

Please check the privacy policy or these third parties’ websites to learn more about how they process your Personal Data under their own responsibility.

Amendments of this privacy Policy

Cellon may amend this Privacy Policy from time to time to ensure that you are fully informed about all processing activities and Cellon’s compliance with applicable Data Protection Legislation. You will be notified of material changes to the Privacy Policy by appropriate means.

Updated on [July 29, 2020]