Privacy Policy

Last update: October 5, 2022

Basic Information Regarding Data Processing

Data Controller
ACOFARMA DISTRIBUTION, S.A. (hereinafter, ACOFARMA)

Purpose of the processing

• Website features.
• Acofarma Network.
• Purchase and sale of products.
• Quality claims.
• Communications, queries and comments.
• Reception of resumes.
• Sending commercial and/or promotional communications in electronic format to Acofarma clients and Cooperative members.
• Sending commercial and/or promotional communications in electronic format to those who have subscribed to our newsletter.

Legitimation of the processing
The processing of your data may be based on the execution of a contract; consent and/or legitimate interest.

Recipients
Data will not be transferred to third parties unless it is based on your consent, the execution of the contract, or another sufficient legal basis.

Rights
Access, rectification, deletion, opposition, limitation of processing, data portability, not to be subject to automated individual decisions and to revoke the consent given, as well as to file a claim with the Spanish Data Protection Agency, if deemed appropriate. You can exercise your rights and ask any questions you may have at informatica@acofarma.com

Additional information
You may consult detailed information about the protection of your data below.

1. Identity and contact details of the Data Controller

Under the terms of the applicable data protection regulations and, in particular, 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 (hereinafter, the “GDPR”) and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter, the “LOPDGDD”), the Data Controller is:

2. Compliance with applicable regulations

ACOFARMA has adapted the Website to the GDPR and the LOPDGDD. To this end, it has implemented those policies, alongside technical and organizational means and procedures to guarantee and protect the confidentiality, integrity and availability of your personal data.

The transfer of data by the user of ACOFARMA’s services through the Website is done voluntarily and the user is informed prior to processing of the use and purposes thereof.

3. Principles we apply to your personal information

The data provided to ACOFARMA by different means, whether these are online or offline contact forms or any other procedure used to collect your data, shall be carried out in accordance with current data protection regulations, and for the sole purpose of providing the service that has been shared with you.

In the processing of your personal data, we apply the following principles that
comply with the requirements of the GDPR:

• Principle of legality, loyalty and transparency: We will always have a legal basis for processing your personal data for one or more specific purposes, which will inform you of in advance with full transparency. ACOFARMA informs you that only the information necessary to achieve the purpose of the processing is collected and only the data you have provided will be processed for the purposes for which you were informed.
• Data minimization principle: We will only request the data that is strictly necessary in relation to the purposes reported.
• Principle of limitation of the conservation period: Personal data will be kept for the time strictly necessary until the purpose for which it was collected is concluded, and as long as the reason that legitimized the processing of this personal data is maintained. Once the cause that legitimized the processing has ended, the personal data will be kept duly blocked during the limitation period of the actions that may arise from the relationship maintained between the parties and/or the legally established conservation periods.
• Principle of integrity: Your data will be processed in such a way as to ensure adequate security and confidentiality of personal data. Please note that we take all necessary precautions to prevent unauthorized access or misuse of data by third parties.
• Confidentiality principle: ACOFARMA, as Data Controller, guarantees the confidentiality in the processing of all personal data of the User to which it has access. The Data Controller, like any other person involved in any phase of the processing, is subject to the strictest professional secrecy, with a special commitment to adopt the necessary levels of protection and measures, both technical and organizational, to guarantee the security of personal data and prevent its alteration, misuse, loss, theft, processing or unauthorized access.
• Data accuracy principle: All information provided by the User to ACOFARMA must be truthful, and the User will be solely responsible for any false or inaccurate statements made and for any damages caused to ACOFARMA or third parties.

ACOFARMA reserves the right to exclude from its services any User who has provided false information, without prejudice to any other legal action that may be taken.

4. Processing of personal data

4.1. Recogida y tratamiento de datos personales

By providing us with your data through the Website, online or offline forms or by any other means, the User guarantees that these are true, accurate, complete and up to date, and accepts responsibility for any direct or indirect damage or harm that may be caused as a result of failure to comply with this obligation.

In the event that the User provides ACOFARMA with third party data, the User must have their consent and undertake to transfer to them the information contained in this clause, releasing ACOFARMA from any liability in this regard. Nevertheless, ACOFARMA may carry out verifications to confirm this fact, adopting the corresponding due diligence measures, in accordance with data protection regulations.

4.2. Finalidades del tratamiento

The purposes of the processing carried out by ACOFARMA on the User’s personal data are:

4.3. Categoría de Datos

In accordance with the aforementioned purposes, ACOFARMA collects and processes the following categories of User data:

Regarding queries or job applications made via the online chat, and in the forms available on the contact, resume submission and comment posting pages, it is permitted to briefly explain the reason for the query, personal presentation or comment, respectively. Please note that personal queries cannot be answered in those locations except those strictly required by current legislation. Under no circumstances will the User communicate data of special categories (such as, for example, health, religion data, etc.). In doing so, the User releases ACOFARMA from all liability. In the event that inappropriate queries or content are submitted, ACOFARMA will proceed to delete them.

4.4. Elaboración de perfiles

In order to achieve the stated purposes, specifically those relating to the sending of commercial and/or promotional communications by electronic means informing you of the activities, services, promotions, advertising, news, offers and other information about ACOFARMA services, automated decisions will be made, including the creation of profiles, in order to send you personalized communications based on your needs and situation.

5. Data processing by third parties and transfer

Depending on the purposes for which personal data is collected, your personal data
may be processed by:

• Authorized personnel of ACOFARMA or its representatives acting on its behalf, subject to the applicable data protection regulations in force.
• Public Administrations, Authorities and Bodies, including Courts and Tribunals, when required by applicable regulations.
• Third-party external service providers that ACOFARMA hires and that are data processors [advertising agencies, IT service providers that process information, hosting servers, database support maintenance, software and applications]. All of the above shall take place only after carrying out the necessary measures to ensure that we can share said information and after having signed a data processing contract with our data processors, in compliance with data protection regulations.
• Cooperatives or member companies of ACOFARMA in their capacity as data processors or assignees when there is a basis that legitimizes such processing.
• Third parties with which ACOFARMA maintains collaboration agreements to offer promotions and discounts to interested parties on products of interest, such as third-party pharmaceutical laboratories or pharmaceutical distribution cooperatives.

If there is a sale, merger, consolidation, change in corporate control, substantial transfer of assets, reorganization or liquidation of ACOFARMA, then, at our discretion, we may transfer, sell or assign the information collected on the Website to one or more relevant parties.

6. Safety measures

ACOFARMA adopts the security levels required by the GDPR appropriate to the nature of the data being processed at any given time for its activity. In this sense, it uses encryption techniques that do not allow a third party to trace the identity of the User who interacts with our services. Likewise, it may also carry out secure techniques to anonymize the personal data it processes in order to carry out its activity. However, technical security in a medium such as the Internet is not impregnable and there may be malicious actions by third parties, although ACOFARMA uses
all means at its disposal to prevent such actions.

7. International data transfer

We do not transfer the User’s personal data to third parties outside the European Union. In the event of international data transfers, all appropriate technical and organizational measures will be taken to ensure data security.

8. Rights of interested parties and their exercise.

In accordance with the GDPR and the LOPDGDD, Users may exercise the following rights:

• Right of access: The User may ask ACOFARMA if it is processing their data and, if so, be able to access such data.
• Right of rectification: The User may request rectification of data if it is inaccurate or incomplete.
• Right to request the deletion of your data, where possible. In any case, when the User exercises this right, all personal data linked to his/her account, as well as the information and content included in his/her profile, will be deleted and will remain blocked until the end of the legal period provided for. Likewise, if the User exercises the right to delete the data necessary for ACOFARMA to provide the services of the Website, ACOFARMA will be obliged to terminate its relationship with the User, proceeding to cancel the service, without the right to any claim on the part of ACOFARMA.
• Right to request limitation of your processing: In this case, we will only retain them for the exercise or defense of claims.
• Right to object to processing: ACOFARMA will stop processing personal data, except when it must continue to be processed for reasons of compelling legitimate interest or for the exercise or defense against possible claims.
• Right to data portability: In the event that the User wishes for their data to be processed by another data controller, ACOFARMA will facilitate the transfer of their data to the new controller if both parties have the necessary technical means to do so.
• Right not to be subject to a decision based solely on the automated processing of your personal data.
• Right to revoke consent: If the User has given consent for a specific purpose, they may withdraw it at any time, without affecting the legality of the processing based on the consent prior to its withdrawal.
• Right to file a complaint with the Spanish Data Protection Agency: If you consider that there has been a violation of data protection legislation regarding the processing of your personal data (https://www.aepd.es/en)

To exercise your rights, you can use the models and forms available on the official website of the Spanish Data Protection Agency (https://www.aepd.es/en/rights-and-duties/know-your-rights), and write to the registered office of ACOFARMA or to the email address informatica@acofarma.com, REF: “Data Protection”.

9. User Consent

The User declares to have read and expressly accepted this Privacy Policy.

The User undertakes to release ACOFARMA from any possible claim, fine or sanction that it may be forced to bear as a consequence of the User’s failure to comply with the duty described in this paragraph.

10. Changes in the privacy policy

We will only use personal data in accordance with the Privacy Policy in force at the time such data is collected.

ACOFARMA reserves the right to modify this Privacy Policy at any time, effective from the date of publication of such modifications on the Website, so it is recommended to visit it each time you access it. If at any time we decide to use personal data in a manner different from that stated at the time of collection, the User will be notified by email, provided we have the email address. At that time, you will be given the option to opt out of other uses or disclosures of the personal information you provided to us prior to the change in our Privacy Policy.

In the event that any clause of this Privacy Policy is canceled or considered void, the remaining conditions will not be affected, fully maintaining their validity and effect, in accordance with the current regulations applicable at any given time.

11. Applicable legislation

The privacy of all information provided, both by the User through the different personal data request forms, and that accessible through the Website, is regulated by current data protection regulations, in particular, by the RGPD and the LOPDGDD.

12. Cookies

Access to the Website may involve the use of cookies. Cookies are small amounts of information that are stored in the browser used by each user so that the server remembers certain information that can be used later. This information allows us to identify you as a specific user and to save your personal preferences, as well as technical information about the use and operation of the Website.

Users who do not wish to activate cookies or wish to be informed before they are stored on their devices may configure their own device to this effect. For more information, please check our Cookies Policy.