PERSONAL DATA

HORUS PHARMA is committed to protecting the personal information and privacy of visitors to the Website and of any person using its Services in general.

The purpose of this Personal Data Protection and Cookies Policy is to inform you:

• The types of personal data we collect about you
• How your personal data is processed by HORUS PHARMA and its possible partners and subcontractors
• The terms and conditions of use of your personal data and your rights in this respect, in compliance with applicable European and French legislation
• All operations on your personal data are carried out in compliance with the regulations in force and in particular with Regulation No. 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR"), and with any applicable national legislation on data protection.

1. DEFINITIONS

Personal data - any information relating to an identified natural person or a person who can be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to that person.

File - any structured and stable set of personal data accessible according to specific criteria.

Data subject - the natural person to whom the data undergoing processing relate;

Data controller - the entity which collects and processes personal data;

Data processing - any operation or set of operations which is performed upon personal data, whatever the process used, including collection, recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction;

Recipient - any person entitled to receive communication of the data other than the Controller, the Processor, and the persons who, by virtue of their functions, are responsible for processing the data;

Authorised third parties - the authorities legally entitled to request the data controller to communicate personal data to them in the context of a particular mission or the exercise of a right of communication;

2. IDENTITY OF THE DATA CONTROLLER

Laboratoire HORUS PHARMA

148 avenue Georges Guynemer,

CAP VAR,

06700 Saint-Laurent-du-Var, France

3. PROCESSING OF PERSONAL DATA

In the course of its business, HORUS PHARMA collects data about you. This data is processed in accordance with the purposes set out at the time of collection, some information being compulsory and others optional, as indicated on the collection forms.          

Furthermore, HORUS PHARMA may collect personal data for other purposes, taking care to obtain the prior consent of the persons concerned.

3.1. PROCESSING IN THE CONTEXT OF THE WEBSITE

The purpose of the processing carried out on our website https://www.horus-pharma.be/gb is to allow:

• To contact us by means of a form made available to you
• To compile statistics on the number of visitors to the site
• To manage the possibility of sharing content on social networks

The collection of data is based on your consent, which you express by accepting the deposit of cookies or by ticking the associated box on the collection form or by writing to us directly.

Processing may be based on HORUS PHARMA's legitimate interests, in particular for the proper functioning of the website.

HORUS PHARMA may collect the following data from you:

Contact form

Identification, professional and contact data: name, first name, e-mail address, telephone number, subject of messages

Statistics ; Cookies and other tracers

Connection data: pages consulted by the user, date and time of consultation, geographical location, source of the connection (social networks, search engine, partner site, directory).

3.2. PROCESSING IN THE CONTEXT OF COMMERCIAL PROSPECTING

The purpose of the processing carried out in the context of commercial prospecting is to enable :

• Contract management (e.g. management of orders, delivery, performance of service or supply of goods, invoices and payments);
• Management of loyalty programmes;
• Keeping general accounts and any subsidiary accounts that may be attached to them;
• The establishment of financial statistics;
• Carrying out customer satisfaction surveys and studies, including surveys, product tests and sales statistics carried out by the organisation concerned;
• Management of complaints, after-sales service and guarantees;
• Carrying out sales and marketing activities (sending advertising messages, competitions, sponsorship, promotions, surveys);

The processing is based on HORUS PHARMA's legitimate interest, in particular for the development of the network with healthcare professionals.

HORUS PHARMA is likely to collect the following data from you:

• Identification data: surname, first name, telephone number, fax number, e-mail, postal address.
• Professional data: position or function, department, speciality.

You can object to communications from us at any time by clicking on the relevant link in the e-mails.

3.3. PROCESSING IN THE CONTEXT OF CONTRACTUAL RELATIONS

The purpose of the processing carried out in the context of the contractual relationship is to enable:

• Management of contracts, orders, deliveries, invoices, accounting and customer relations.
• The elaboration of commercial statistics.
• Management of requests for access, rectification and opposition rights.
• Management of unpaid invoices and disputes.
• Management of people's opinions on products, services or content. La collecte des données repose sur l’exécution du contrat signé avec HORUS PHARMA.

The processing may be based on HORUS PHARMA's legitimate interest, the customer file being considered as representative of the customer base, defined as an essential element of the business under the law of 17 March 1909. 

HORUS PHARMA is likely to collect the following data from you:

• Identification data: surname, first name, title, telephone number, fax number, postal address, e-mail address, internal customer code.
• Professional data: service, speciality, delivery address, opinions on products, customer comments, correspondence with the after-sales service, date of participation in promotional operations, requests for documentation, samples given, purchase history, amount, reason and responsibility for the complaint, nature of the prizes offered, origin of the order, origin of the sale, periodicity, product purchased, quantity, return of products.
• Economic data: credit notes, unpaid invoices without excluding the person, payment methods, cheque number, receipts, discounts granted.
• Computer data: internet address, date, time, page visited, protocol of the visitor's computer.

3.4. TREATMENT IN THE CONTEXT OF MEDICAL INFORMATION

The purpose of the processing carried out in the context of medical information is to allow:

• Management of medical information (responses relating to products received via contact forms and telephone calls).

The collection of data is based on compliance with the legal obligations to which HORUS PHARMA is subject, in particular the Public Health Code.

HORUS PHARMA may collect the following data from you:

• Identification data: surname, first name, telephone number, e-mail, postal address, origin of the request, name of the person receiving the request, date of the request, description of the request, nature of the request, name of the product concerned.

3.5. TREATMENT IN THE CONTEXT OF VIGILANCE

The purpose of the processing operations set up in the context of vigilance is to enable:

• Vigilance to be implemented within the framework of monitoring a product placed on the market (pharmacovigilance, materialovigilance, nutrivigilance, biovigilance, cosmetovigilance), in particular through the recording, evaluation and declaration of cases of vigilance.

The collection of data is based on compliance with the legal obligations to which HORUS PHARMA is subject.

HORUS PHARMA may collect the following data from you:

• Identification data: surname, first name, initials, weight, sex, height, date of birth, telephone number, e-mail, postal address, alphanumeric identification number or code.
• Identification data of the patient's health professional: surname, first name, telephone number, fax number, e-mail, postal address, speciality.
• Sensitive data: personal or family history, risk factors, information relating to the method of prescription, associated diseases or events, nature of the adverse reaction(s), test results, treatments administered.

4. RETENTION PERIODS

5. RIGHTS OF INDIVIDUALS

In accordance with Regulation (EU) 2016/679 on the protection of personal data, you have the right to request from the controller access to your personal data, rectification or erasure of your personal data, and restriction of the processing of your personal data. 

You also have the right to object to the processing of your personal data on legitimate grounds, as well as the right to object to your data being used for commercial prospecting purposes.

Finally, you have the right to set out general and specific instructions on how you wish these rights to be exercised after your death.

If you feel, after contacting us, that your rights with respect to your personal data are not being respected, you may lodge a complaint with the CNIL or the supervisory authority in your place of residence.

To exercise these rights or if you have any questions about the processing of your data in this system, you can contact our Data Protection Officer (DPO), providing proof of your identity.

To exercise your rights, you can contact the DPO:

By e-mail: RIL@horus-pharma.be

By post: RIL Horus Pharma Belux, Lenniksebaan 451- B-1070 Brussel - BELGIE.

6. RECIPIENTS

The recipients of your personal data are the relevant departments of HORUS PHARMA and its subcontractors within the framework of their missions.

This personal data is not communicated to third parties. However, HORUS PHARMA reserves the right to transmit the personal data of authorised third parties in order to meet its legal obligations, and in particular if it is obliged to do so by judicial requisition.

For certain services, such as sharing on social networks and cookies, our partners have access to your data.

HORUS PHARMA requires all its service providers and partners to process personal data in accordance with confidentiality and security commitments.

7. SECURITY

Considering the evolution of technologies, the costs of implementation, the nature of the data to be protected as well as the risks for the rights and freedoms of individuals, HORUS PHARMA implements all appropriate technical and organisational measures to guarantee the confidentiality of the personal data collected and processed and to ensure a level of security adapted to the risk.

HORUS PHARMA ensures the security of your personal data by implementing enhanced data protection through the use of physical and logical security measures.

HORUS PHARMA has defined a personal data protection policy and informs any person acting under its authority who accesses this information of its confidential nature. In addition, HORUS PHARMA ensures that its technical service providers who may have knowledge of personal data respect the same confidentiality.

However, it is the responsibility of each user to ensure the security of personal data transmissions via the Internet. HORUS PHARMA cannot be held responsible for the transmission of personal data via the Internet.

8. TRANSFER OF PERSONAL DATA

Your data may be transferred to a country outside the European Economic Area.  HORUS PHARMA has put in place the following safeguards to ensure an adequate level of protection for your information:

The transfer is framed, in accordance with the requirements of European Regulation n°2016/679/EU of 27 April 2016, by:

• Standard protection clauses adopted by the European Commission: Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries under Regulation (EU) 2016/679 of the European Parliament and the Council.

9. SOCIAL NETWORK BUTTONS

You have the option of sharing pages of interest to you on social networks by clicking on sharing buttons.

The collection of information through social network sharing buttons is subject to the privacy policies of those third parties. We invite you to read the policies of these social networks to find out how your personal data is used.

10. COOKIES

Definition

Cookies are data stored on a user's terminal equipment and used by the site to send information to the user's browser, allowing the browser to send information back to the originating site (e.g. a session ID, language choice or date).

Cookies enable status information to be retained for the duration of the cookie's validity when a browser accesses different pages of a website or when the browser returns to that website at a later date.

Only the sender of a cookie can read or modify the information contained in it.

Several types of cookies are likely to be used by the site:

• Cookies that are strictly necessary for navigation on the site and to ensure its proper functioning;
• Cookies that allow us to establish traffic statistics;

The advertising content on our website may contain cookies issued by third parties. Such cookies may also be deposited on your terminal during your navigation. The issue and use of these cookies by third parties are subject to the privacy policies of these third parties.

Third party cookies and trackers:

• https://fr.matomo.org/

Consent

When you browse our website, the deposit and reading of cookies enables us to analyse your browsing and measure the audience of the www.horus-pharma.be website.

You can choose whether to authorise the deposit of cookies used by our site and not essential to its operation. They will only be deposited if you accept their use. To configure or modify your choice at any time, you can use our cookie management tool.

If you set your browser to refuse cookies, certain functions, pages and areas of the site will not be accessible, for which we cannot be held responsible.

We would also like to draw your attention to the fact that, when you oppose the installation or use of a cookie, a refusal cookie is installed on your terminal equipment.

If you delete this refusal cookie, it will no longer be possible to identify you as having refused the use of cookies.

Similarly, when you consent to the installation of cookies, a consent cookie is installed. The consent or refusal cookie must remain on your terminal equipment.

11. UPDATES

This policy is effective as of 2021-11-30.

To check for updates to our Policy, please visit this page regularly.

DO YOU HAVE ANY QUESTIONS?

The DPO of HORUS PHARMA is at your disposal for any further information concerning the use of your data.

Please send your request by post to RIL Horus Pharma Belux, Lenniksebaan 451- B-1070 Brussel – BELGIE, or at RIL@horus-pharma.be.