BPL Bioproducts Laboratory GmbH (“BPL”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit this Microsite at www.coagadex.eu – (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how BPL collects and processes your personal data through your use of this Microsite.
This Microsite is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Have a question about something in this policy?
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: BPL Bioproducts Laboratory GmbH
Email address: [email protected]
Postal address: Dornhofstrasse 34, 63263 Neu-Isenburg, Germany
You have the right to make a complaint at any time to the relevant data protection authority in the country where you live. We would, however, appreciate the chance to deal with your concerns before you approach the relevant authority so please contact us in the first instance.
Changes to the privacy policy
We keep our privacy policy under regular review. This version was last updated on October 2020.
Third-party links
This Microsite may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Microsite, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We , use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Microsite.
- Usage Data includes information about how you use this Microsite, products and services (including the country in which you confirm you are located and the language in which you view the information provided on this Microsite).
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Microsite feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity [Contact, Profile] and Usage Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- access the Microsite and confirm the country in which you are located; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with this Microsite, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy [LINK] for further details.
- Third parties or publicly available sources. We will receive Technical Data about you from various third parties Technical Data from analytics providers such as Google based outside the United Kingdom and European Union.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To process your instructions and provide the information on this Microsite in the appropriate language | Identity
|
Necessary for our legitimate interests (to provide users of our products with access to the relevant patient information in accordance with European Medicines Agency or other regulatory requirements) |
| To redirect you to third party websites where you wish to report an Adverse Event (e.g. side effects) or other pharmacovigilance information relating to one of our products | Identity
Technical Usage |
Necessary for our legitimate interests (to ensure Adverse Event and pharmacovigilance information is accurately recorded)
Necessary to comply with a legal obligation |
| To administer and protect our business and this Microsite (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity
Technical |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, and to prevent fraud)
Necessary to comply with a legal obligation |
| To deliver relevant website content to you | Identity
Usage Technical |
Necessary for our legitimate interests (to study how customers use this Microsite, to develop it, and to grow our business) |
| To use data analytics to improve our Microsite | Technical
Usage |
Necessary for our legitimate interests (to define types of customers using this Microsite, to keep it updated and relevant, and to develop our business) |
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Internal Third Parties as set out in the glossary.
- External Third Parties as set out in the glossary.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We share your personal data within BPL’s group. This may involve transferring your data outside the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will we use your personal data for?
We will only keep your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. When deciding the appropriate retention periods, we will take into account:
- The amount, nature and sensitivity of the personal data, risk of potential harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means.
- The duration for which your personal data is required to performance the services offered by the Microsite and the purpose for which it was collected; and
- Any legal and regulatory obligations under applicable law, contract or with regard to any statutory obligations.
In some circumstances we may your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
- Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.
- Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
- Your right to withdraw consent – You have the right to withdraw consent at any time where we are relying on consent to process your personal data.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best information and service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
Other companies in BPL’s group and who are based inside and outside the European Union, including Bio Products Laboratory Limited.
External Third Parties
Service providers acting as processors based in the United Kingdom or the European Union who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- The European Medicines Agency, the Medicines and Healthcare products Regulatory Agency and other regulators and authorities acting as processors or joint controllers based in the United Kingdom or the European Union who require reporting of processing activities in certain circumstances.
- Google LLC, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, United States of America.