PRIVACY POLICY

ALTA PHARMACEUTICALS LTD for the website www.altaph.eu

(information provided pursuant to Article 13 of the GDPR)

This document provides information about the different categories of data we collect about individuals who visit this website; about the processing, including collection, recording, storage, use of personal data; the grounds and purposes, in relation to the categories of personal data processed and the protection of personal data.

Administrator details

Administrator	Alta Pharmaceuticals
Address	Bulgaria, Sofia 1618, 118 Bulgaria Blvd., BC Abacus, floor 3
GDPR Contact Point	gdpr_contact@altaph.eu​
Phone	02 854 97 00

 

Alta Pharmaceuticals Ltd. is a licensed wholesaler of pharmaceutical products, medical devices, nutritional supplements and cosmetics.

Personal data

According to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), personal data means any information relating to an identified or identifiable natural person (“data subject”); An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Alta Pharmaceuticals Ltd. strictly adheres to the processing of the minimum possible amount of personal data. This notice aims to clarify what personal data we process and what your rights are in this regard.

Categories of data we process

The use of the website https://altaph.eu/ in the mode of viewing the general functionalities of the site can be done without the need to enter your personal data.

If you wish to benefit from the full functionalities in connection with the services provided by Alta Pharmaceuticals Ltd., the processing of your personal data will probably be necessary. We may process personal data for the purpose of implementing pre-contractual and contractual relationships, when providing information requested by you, for example, about our business, including our products and services, when you request us to provide you with information via an inquiry form, when applying for a job through an advertisement on the website, in the presence of a legitimate interest for you or for us.

The grounds on which we process your personal data are the performance of contractual relationships, on the basis of consent, compliance with a legal obligation or for the purposes of legitimate interests.

Personal data we may request includes:

• Name
• Organization (which you represent, work for, or on behalf of which you are contacting us)
• Email address
• Address
• Phone
• Preferred language
• Your interests, education, professional experience, qualifications, and any other information voluntarily submitted by you, included in documents you send us.

Data collection order

We collect personal data in several ways, including through registration, when you provide data when concluding a contract, when you contact us directly, through contact details, through the contact forms on our site – inquiry form, applications, surveys in connection with your inquiries, when you browse our website through the use of cookies.

Registration on the Alta Pharmaceuticals Ltd. website – https://altaph.eu/ is carried out with a code that identifies partner companies in the pharmaceutical sector.

Our website is not intended for use by persons under the age of 14 and we do not knowingly collect personal data from such persons. If a person under the age of 14 needs to use any of the forms on our website that require the provision of personal data, then the site’s functionalities should be used by a parent/guardian on behalf of the child.

Grounds for data processing

The grounds on which we process your personal data are:

 – the implementation of contractual relations;

In order to enter into a contract and to perform our obligations under it, we need to process certain information, including information provided by you. Some of this information may be personal data.

We may use the data you provide to:

• to verify your identity for security purposes;
• making a sale or delivery of products we offer;
• to provide you with other related services;
• to send you suggestions or advice about our products, services, including how to make the most of the features available when using our website.

We will continue to process this information until the relevant pre-contractual and/or contractual relationship ends (i.e. as long as your registration is active). It is possible that the processing of some personal data may continue in order to comply with regulatory requirements (e.g. for tax purposes).

– on the basis of consent;

By certain actions, for example when you browse the website https://altaph.eu/ or request that we provide you with more information about our business, including our products and services, through direct marketing, you consent to us processing information that may constitute personal data.

For example, when we want to receive feedback from you (collect your opinions), we will ask for your explicit consent in advance.

Whenever possible, we seek to obtain your explicit consent to process this information, for example, by asking you to accept the use of cookies when using the site https://altaph.eu/ .

Sometimes you may give your consent indirectly, such as when you send us an email message to which you reasonably expect us to respond.

Except where you consent to the use of your information for a specific purpose, we do not use your information in a way that personally identifies you.

– fulfillment of a legal obligation;

Sometimes we need to process your information to comply with a legal obligation.

We may also be required to provide information to judicial authorities if they request it, or if they have a relevant document – e.g. a warrant, search warrant or court order.

– on the basis of legitimate interests.

We may process information based on a legitimate interest for you or for us. For example, we may process your data for the purposes of:

• keeping records for the proper and necessary administration of our business;
• optimizing our business processes;
• responding to unsolicited communication from you that we believe you expect a response to;
• protection of our information systems;
• protection and enforcement of the legal rights of any party;
• protect your interests, in cases where we believe we have a reason and obligation to do so.

Purposes for processing Personal Data

We may use the data you provide to:

• to verify your identity for security purposes;
• making a sale or delivery of products we offer;
• performance of contractual relations;
• to provide you with other related services;
• to provide you with information you have requested;
• to send you suggestions or advice about our products, services, including how to make the most of the features available when using our website;
• selection of employees who applied for job advertisements through the website;

We may also process your data for the purposes of:

• performing data analysis for our business purposes, to optimize the site, to improve communication, to improve our products and services;
• keeping records for the proper and necessary administration of our business;
• optimizing our business processes;
• responding to unsolicited communication from you that we believe you expect a response to;
• protection of our information systems;
• protection and enforcement of the legal rights of any party;
• protect your interests, in cases where we believe we have a reason and obligation to do so.

Your data may be processed in connection with an acquisition, merger, division or liquidation of the company or part of its business by third parties, in which case we rely on our legitimate interest.

It is also possible that your data may be processed within the group of companies to which it belongs or which belong to Alta Pharmaceuticals Ltd., for internal administrative purposes, in which case we rely on our legitimate interest.

Period for which personal data will be stored

Unless otherwise stated in this Privacy Policy, we retain your personal data only for as long as required by us:

• to provide you with the goods/services /information you have requested;
• to comply with other laws and legal requirements, including for the period required by tax, medical or other public authorities;
• until the relevant pre-contractual and/or contractual relationships are terminated; as long as you have an active registration on the site, as it is possible that the processing of some personal data may continue in order to comply with regulatory requirements (e.g. for tax purposes).
• in connection with a possible claim or defense in court.

Recipients or categories of recipients of your personal data

These can be:

• Employees of Alta Pharmaceuticals Ltd.;
• Data processors on behalf of Alta Pharmaceuticals Ltd.;
• Companies related to Alta Pharmaceuticals Ltd.
• Entities that maintain our information systems;

(The categories mentioned here also include the persons who process data on the website where Alta Pharmaceuticals Ltd. customers register )

Transfer of data to a third country or an international organization

Alta Pharmaceuticals Ltd. does not transfer your data to a third country or an international organization.

In the event that, notwithstanding the above, our partners and/or companies from the corporate group of the personal data controller in a third country, including outside the EU/EEA, gain access to your Personal Data, each transfer will be secured with appropriate safeguards provided for in the GDPR, such as standard data protection clauses (so-called standard contractual clauses) adopted by the European Commission.

Rights you have in relation to the personal data you provide

In relation to the personal data you have provided to us, you have the right to request from us access to, correction or deletion of your personal data, or restriction of their processing, as well as the right to object to the processing of your data, as well as the right to data portability.

The right to complain to a supervisory authority

You have the right to lodge a complaint with a supervisory authority. The supervisory authority in the Republic of Bulgaria, within the meaning of the applicable legislation, is the Commission for Personal Data Protection.

Data protection and security

We use appropriate organizational, technical, administrative and physical measures to protect Personal Data. Unfortunately, no organization and information processing system can guarantee absolute information security.

Cookies

The websites of Alta Pharmaceuticals Ltd. use cookies . “Cookies” are text files that are stored on a computer system via an internet browser.

Many websites and servers use cookies. Many cookies contain a so-called “cookie ID”. A cookie ID is a unique identifier for a cookie. It consists of a string of characters that can be assigned by websites and servers to the specific internet browser in which the cookie is stored. This allows the visited websites and servers to distinguish the individual browser of the data subject from other internet browsers that contain other cookies. A specific internet browser can be recognized and identified by the unique cookie ID.

Through the use of cookies, Alta Pharmaceuticals Ltd. can provide users of this website with more user-friendly services that would not be possible without the use of cookies.

With the help of a cookie, the information and offers on our website can be optimized with regard to the data subject. Cookies allow us to recognize users of our website. The purpose of this recognition is to make it easier for users to use it. For example, the data subject of a website that uses cookies does not have to enter access data every time the website is called up, because this is taken over by the website and the cookie is thus stored on the data subject’s computer system.

The data subject may at any time prevent the use of cookies on our website by means of a corresponding setting in the Internet browser used and thus permanently refuse the setting of cookies. In addition, cookies that have already been set can be deleted at any time via the Internet browser or other software programs. This is possible with all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website can be used to their full extent.

Collection of general data and information

The Alta Pharmaceuticals Ltd. website may collect a series of general data and information when a user or an automated system calls up the website. This general data and information is stored in the server log files. The collected data may be (1) the types and versions of the browser used, (2) the operating system used by the accessing system, (3) the website from which it reaches our website (so-called referrers), (4) sub- pages, (5) the date and time of access to the website, (6) the Internet Protocol address (IP address), (7) the Internet service provider of the accessing system and (8) any other similar data and information that can be used in the event of attacks on our information technology systems.

When using this general data and information, Alta Pharmaceuticals Ltd. does not draw any conclusions about the data subject. Rather, this information is necessary to: (1) provide the content of our website correctly, (2) optimize the content of our website as well as its advertising, (3) ensure the long-term viability of our information technology and web technologies, and (4) provide law enforcement authorities with the necessary information for criminal prosecution in the event of a cyber attack. Alta Pharmaceuticals Ltd. therefore statistically analyzes the anonymously collected data and information in order to increase the data protection and data security of our enterprise and to ensure an optimal level of protection for the personal data we process. The anonymous data in the server log files is stored separately from all personal data provided by users.

Contact option via website

The website of Alta Pharmaceuticals Ltd. contains information that allows for quick electronic contact with us as well as direct communication with us, which also includes a general address of the so-called e-mail (info@altaph.eu). If the data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted voluntarily by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of these personal data to third parties.

Routine deletion and blocking of personal data

The Administrator processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage, or to the extent determined by the applicable legal acts.

If the purpose of storage is not applicable or if the storage period specified in a regulatory act expires, personal data is routinely blocked or deleted in accordance with legal requirements.

Data protection provisions regarding the implementation and use of Google Analytics (with anonymization function)

On this website, the administrator may integrate the Google Analytics component (with the anonymization function). Google Analytics is a web analytics service. Web analytics is the collection and analysis of data about the behavior of website visitors. The web analytics service collects, among other data, data about the website from which a person came (the so-called referrer), which sub-sites were visited or how often and for how long sub-sites were viewed. Web analytics is mainly used to optimize a website and to perform a cost-benefit analysis of online advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

For web analytics using Google Analytics, the controller uses the application “_gat. _anonymizeIp”. With the help of this application, the IP address of the data subject’s Internet connection is shortened by Google and anonymized when accessing our websites from a Member State of the European Union or from another state party to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the data and information collected, including to evaluate the use of our website and to provide online reports showing the activities of our websites and to provide other services related to the use of our website for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of “cookies” is explained above. By setting the cookie, Google can analyze the use of our website. With each call-up to one of the individual pages of this website, which is operated by the controller and into which a Google Analytics component has been integrated, the Internet browser on the information technology system of the data subject will automatically send data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During this technical procedure, the enterprise Google acquires knowledge of personal information, such as the IP address of the data subject, which serves Google, among other things, to understand the origin of visitors and clicks. “The “cookie” is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits to our website by the data subject. With each visit to our website, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may transmit this personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently refuse the setting of cookies. Such a setting in the internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already used by Google Analytics can be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility to object to the collection of data generated by Google Analytics , which is related to the use of this website, as well as the processing of this data by Google and the possibility to exclude such. For this purpose, the data subject must download the browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics via JavaScript that all data and information about visits to Internet pages should not be transmitted to Google Analytics . The installation of the browser add-ons is considered an objection to Google. If the information technology system of the data subject is later deleted, formatted or newly installed, then the data subject must reinstall the browser add-ons in order to deactivate Google Analytics . If the browser add-on was uninstalled by the data subject or another competent person or is deactivated, it is possible to reinstall or reactivate the browser add-ons.

Further information and the applicable Google data protection provisions can be downloaded at https://www.google.com/intl/bg/policies/privacy/ and at http://www.google.com/analytics/terms/us.html . Google Analytics is further explained under the following link https://www.google.com/analytics/ .

Data protection provisions regarding the implementation and use of Google+

On this website, the administrator can integrate the Google+ button as a component.

Google+ is a social network.

A social network is a social meeting place on the Internet – an online community that typically allows users to communicate with each other and interact in a virtual space. A social network can serve as a platform for exchanging opinions and experiences or enable the Internet community to provide personal or business-related information. Google+ allows users of the social network to include the creation of private user profiles, upload photos, and build a network of acquaintances through friend requests.

Google+ is operated by Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

With each call-up to one of the individual pages of this website, which is operated by the controller and on which a Google+ button has been integrated, the Internet browser of the data subject’s information technology device automatically downloads a screen with the corresponding Google+ button from Google via the corresponding Google+ button component. During this technical procedure, Google is informed of which specific sub-site of our website was visited by the data subject. More detailed information about Google+ can be found at https://developers.google.com/+/ .

If the data subject is logged in to Google+ at the same time, Google recognizes the data subject with each call-up to our website and for the entire duration of his or her stay on our website, which specific pages of our website were visited by the data subject. This information is collected via the Google+ button and Google compares it with the respective Google+ profile associated with it.

Through the Google+ button, Google receives information that the data subject has visited our website if the data subject is logged in to Google+ at the time of calling up our website. This occurs regardless of whether the data subject clicks on the Google+ button or not.

If the data subject does not wish to transmit personal data to Google, he or she can prevent such transmission by logging out of his or her Google+ account before calling up our website.

Further information and Google’s data protection provisions can be retrieved at https://www.google.com/intl/bg/policies/privacy/ . Further references from Google for the Google+ button can be obtained at https://developers.google.com/+/web/buttons-policy .

Update

The Privacy Policy may be subject to changes and updates. In such case, we will reflect the date of the change at the beginning of the Policy, and the changes and updates will be effective with respect to you and your Personal Data after the date of the last revision.

Latest current version from 7-August-2021. Supersedes all previous versions.