Privacy Policy - Eurofarma

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PRIVACY POLICY

We, at EUROFARMA LABORATÓRIOS S.A., private legal entity, enrolled with the Corporate Taxpayers' Registry [CNPJ] under No. 61.190.096/0001-92 ("Eurofarma", "We", "Us"), are committed to seeking the best way to meet the needs of our customers and users ("You"). We are a pharmaceutical company present in over 20 countries that offers high-quality and innovative products and services to improve people's lives. Therefore, in respect to the privacy and personal data of our consumers, we provide You this document ("Policy" or "Privacy Policy").

When You visit or interact with our website or use our services, we may store certain information ("Data" or "Personal Data") about You. We have drafted this Privacy Policy to clarify what Personal Data may be collected, used, shared and stored by Us.

You will accept this Policy when You use our services, visit or interact with the website and, when prompted, affirmatively agree to the use of your Personal Data for each of the purposes described by Us herein. By doing so, You are aware of and in full agreement with how We will use Your information and Your Personal Data. If You do not agree to this Policy, please do not continue to use our services and website or interact with it. We only ask that you explain the reason for your disagreement so that we can improve our products and services. You can contact us at privacidade@eurofarma.com.br. Feel free to contact us at privacidade@eurofarma.com.br.

To make our Policy easier to understand, we have broken it down as follows:

What types of Data do we collect?

1.1. Website visitors

1.2. Consumers

1.3. Healthcare professionals

1.4. Suppliers

Cookies

2.1. What is a Cookie?

2.2. Why do we use Cookies?

3. With whom do we share your Data?

4. Where is your Data stored and where is it shared?

5. What are your rights as a Data subject?

6. How long will your Personal Data be stored?

7. How do we protect your Data?

8. How to contact us?

9. Changes to this Privacy Policy

1. What types of Data do we collect?

The amount and type of information collected by us varies depending on Your use of our products and services. We will collect different Personal Data, i.e., whether You are a consumer, a healthcare professional, or if You are just visiting our site.

To clarify such differences, we have listed below some of the purposes for which your Data may be used depending on the type of interaction You have with us:

1.1 Website visitors

If You are a visitor to the wesite and/or have interacted with our website, Your Data will be used as presented in the table below, subject the corresponding legal bases:

Purpose	Personal data	Legal basis
Access to the website	IP, date and time of access and cookies	Legal Obligation and Legitimate Interest
Assistance via website form	Name, address, e-mail, phone number, whether or not you are hearing impaired, reason for contact, and all the information that You voluntarily provide us through the "message" field	Consent
Adverse event reporting	Rapporteur: Name, email, telephone number, whether or not you are a healthcare professional and whether or not you are affiliated with any healthcare organization Patient: Name, gender, weight, age, height, e-mail, telephone, medication used, history of illness, use of other medications, symptoms, report of the adverse event, and Personal Details of the prescribing physician	Consent

1.2. Consumers

If You are a consumer of our products, in addition to what is described in section 1.1 above, Your Data will also be used, to the extent applicable, as described in the table below, subject to the corresponding legal bases:

Purpose	Personal data	Legal basis
Telephone assistance (may include after-sale information, further details, complaints, compliments, suggestions, among others)	Full name, Individual Taxpayers' Registration [CPF], address, telephone number, e-mail, service report, medication used and further details voluntarily provided by You to Us	Legal Obligation, Legitimate Interest or Consent (depending on the type of service)
Quality deviation analysis and complaints	Name, Individual Taxpayers' Registration [CPF], address, telephone number, e-mail, complaint about suspected product quality deviation, and bank details (for possible compensation)	Legal Obligation, Legitimate Interest and Consent
Satisfaction Survey	Name, phone number, e-mail	Legitimate Interest
Relationship Actions	Full name, Individual Taxpayers' Registration [CPF], address, telephone number, e-mail, service report, medication used and further details voluntarily provided by You to Us	Consent
Assistance and complaints on adverse events (notification and reporting)	Full name, age, gender, Individual Taxpayers' Registration [CPF], address, telephone number, e-mail, medication used, related adverse event, weight, height, age, gender, associated and pre-existing diseases, medical history, concomitant medications, data from the prescribing physician (name, e-mail, telephone number and CRM [Regional Council of Medicine] registration number), bank details – if necessary – and further information voluntarily provided by You to Us	Legal obligation
Social Media Adverse Event Tracking (Facebook, Instagram, Twitter, Reclame Aqui and any media that publishes any report involving a suspected adverse event with Eurofarma products)	Full name, age, gender, address, telephone number, e-mail, Eurofarma product related to the event, data from the prescribing physician (name, telephone number and address) and/or other professionals involved in the patient's assessment or in the dispensing/supplying of the product	Legal obligation

Children's data: some of our services and products may be intended for children, i.e., persons under the age of 12. In such cases, where appropriate, we will seek consent from their parents or legal guardians for the processing of their Personal Data, in accordance with applicable laws.

1.3 Healthcare professionals

If You are a healthcare professional, in addition to what is described in section 1.1 above, Your Data will also be used, to the extent applicable, as described in the table below, subject to the corresponding legal bases:

Purpose	Personal data	Legal basis
Access to website features for healthcare professionals	Professional registration, nationality, Individual Taxpayers' Registration [CPF]	Consent
Assistance and complaints on adverse events (notification and reporting)	Name, e-mail, telefone number, CRM [Regional Council of Medicine] registration number	Legal obligation
Relationship actions (ranging from visits to submission of studies and scientific research, and internal communications)	Full name, age, gender, address, telephone number, e-mail, Individual Taxpayers' Registration [CPF] and further information voluntarily provided by You to Us	Legitimate Interest

1.4 Suppliers

If You are an employee of companies interested in becaming a vendor or partner of Eurofarma, or otherwise represent such companies, Your Data will be used as proposed in the table below, subject to the corresponding legal bases, and also as described in item 1.1 above:

Purpose	Personal data	Legal basis
Website vendor registration	Name, company you represent, Individual Taxpayers' Registration [CPF], e-mail, telephone number, address, and inform if it is a pharmaceutical company.	Consent
Order request	User.	Contract Execution
Issuance of 2nd copy of payment slips	Individual Taxpayers' Registration [CPF] or Corprate Taxpayers' Registration [CNPJ], e-mail.	Contract Execution
After-sale contact	User, e-mail.	Legitimate Interest

We may process additional Data in specific situations, but always on a valid, legitimate and lawful basis that is appropriate to the purpose of processing. Furthermore, it is worth mentioning that we constantly assess the actual need for the use of the Personal Data processed and, when unreasonable, we undertake to delete them immediately.

Cookies

2.1 What is a Cookie?

Cookies are small text files stored in your browser or device. Cookies allow us to recognize Your preferences in order to adapt the website and your navigation to your specific needs. That is, some of your information is saved in this text file, and on a next visit to the website, it recognizes your browser and is able keep your account logged in, among other actions.

Cookies usually also have an expiration date, i.e. some cookies are deleted automatically when You close your browser (session cookies), while others may be stored longer on your computer until they are deleted manually (persistent cookies).

2.2 Why do we use Cookies?

Our websites use the following types of cookies:

(i) cookies that are strictly necessary for our website to run properly, i.e. authenticating logins. Therefore, if You want to visit our websites, You cannot possible to refuse these cookies;

(ii) analytics cookies, to improve the content of our websites, by providing information about how the websites are being used, and enhance user experience. These cookies automatically collect certain Personal Data, i.e., to identify how many times a particular page has been visited; and

(iii) marketing cookies, so that we are able provide the best Product and Service offerings to You, according to your interests.

The use of cookies is based on Eurofarma's the legitimate interest. Some types of cookies can only be blocked, deleted or restricted by setting up browser. Thus, should you wish to block, restrict or delete such cookies, please find further explanations on how to proceed by clicking on the links below. For information related to other browsers, please visit the browser developer's website.

Bear in mind that cookies allow us to offer you a better experience with our products and services. If you block cookies, we cannot guarantee that all features will work properly and you may not be able to access certain areas of our products. In addition, it is very likely that certain features and pages will not work properly.

It must be clarified that we are not responsible for the use of cookies by third parties. Please be aware that cookies placed by third parties may continue to monitor your online activities even after you have left our website and we recommend that You clear your browsing history regularly.

To obtain more detailed information about the processes commented above, feel free to contact us at privacidade@eurofarma.com.br. Our team is committed to respond your inquiry, provided that it does not infringe any applicable legislation and/or Eurofarma's trade secrets and intellectual property.

3. With whom do we share your Data?

In some situations, we may operate jointly with other companies in various activities, including for data hosting, analytics, and market intelligence. Accordingly, we reserve the right to share your information, including Personal Data, only with the companies listed below. We will adopt, whenever possible, mechanisms to anonymize such data in order to preserve your privacy to the full extent possible.

Accordingly, we may share your Personal Data with the following companies:

Our vendors: We need to engage with a number of vendors to operate our services, and some of them may handle the Personal Data that we collect. This includes companies that provide data hosting services, customer care services, authentication and registration validation services, advertising companies, and others. To the extent possible, we carefully evaluate our suppliers and enter into information security and Personal Data protection contractual obligations with them in order to minimize risks to Data Subjects, but unfortunately we cannot guarantee proper handling by third parties using, disclosing and protecting Personal Data in accordance with their respective privacy policies.
Business partners: In addition to our vendors, we may occasionally share Personal Data with our business partners in order to enable us to offer you a certain product or service or a special condition. As with our suppliers, we make every effort to carefully evaluate our business partners and enter into information security and Personal Data protection contractual obligations with them in order to minimize risks to Data Subjects, but unfortunately we cannot guarantee proper handling by third parties using, disclosing and protecting Personal Data in accordance with their respective privacy policies.
Clinical Research Partners: in certain situations, Eurofarma needs to engage with clinical research centers and other partners, i.e. to conduct studies to assess the efficacy and safety of a new drug. In this case, and in case You expressly agree to participate in such research, certain Data can be shared among the companies that take part in such study, as well as with ANVISA (Brazil's National Health Surveillance Agency), in order to guarantee the efficacy and development of a certain drug. It should be stressed that we will always handle such Data according to what was informed at the occasion and according to the applicable legislations.
Marketing and communication delivery: If You are a Healthcare Professional, we will probably use your data to deliver communications and marketing content. For such purpose, we partner with marketing companies and use data analysis systems, mailing tools and APIs in order to send communications, target content and advertisement, according to your interests. Therefore, Data may be shared between Eurofarma and other companies, especially registration data, unique identifiers, IP addresses, cookies, behavioral data, data on the use of our services and platforms (analytics), which may be used to measure the efficiency of online advertising.
Eurofarma Group Companies: We may transfer Data among Eurofarma's companies in order to perform the due service to our clients and consumers, in addition to ensuring the compliance with Eurofarma's legal and regulatory obligations, especially when these are unique and/or integrated, among other reasons.
To safeguard and protect Eurofarma's rights: We reserve the right to access, read, preserve and disclose data that we deem necessary to comply with a legal obligation or a court order; meet regulatory demands with Anvisa (Brazil's National Health Surveillance Agency) or other entities; protect the rights, property or safety of Eurofarma, our employees and customers.

4. Where is your Data stored and where is it shared?

We are a 100% Brazilian company and our operations are performed within the national territory. We are thus subject to the Brazilian laws related to the protection of Personal Data. The Data we collect is hosted on our own servers located in Brazil, but certain Data is hosted on Microsoft servers located in Brazil.

All international transfers involve only companies that demonstrate that they are in compliance or in the process of compliance with applicable laws and maintain a level of compliance similar to or even more stringent than that provided by applicable Brazilian law.

By using our services or providing Personal Data to us, You consent to the processing and international transfer of such data to the locations identified above. Such data may be subject to local law and relevant rules.

5. What are your rights as a Data Subject?

Personal Data is yours, and Brazilian law ensures You a number of rights related thereto. We are committed to enforcing such rights and in this section You will find explainations on how You can exercise such rights with Us.

You can find out whether we hold Personal Data about You, and how to access it.
You can also request this information by emailing us at privacidade@eurofarma.com.br (as a security measure, we may request additional information to verify your identity and prevent fraud).
You may request Us to correct Personal Data that we hold about You.
Upon verifying that any of your Personal Data is incorrect or out-of-date, You may request corrections to your Personal Data. To do so, please contact us at privacidade@eurofarma.com.br.
You may request Us to delete your Personal Data, in whole or in part.
You may call on Us for the deletion of your Personal Data, in whole or in part. Fill out the form on the link or e-mail us at privacidade@eurofarma.com.br. Two important reminders: (i) we may occasionally run checks to verify your actual identity to ensure that there is no fraud, and (ii) some Personal Data may not be deleted because of legal obligations, contractual performance, or other reasons, but in these cases we will maintain our commitment to confidentiality and protection of such data.
You may restrict our processing of your Personal Data.
You may restrict the processing of your Personal Data by Us in the following ways:
(i) On any website, via browser. If you are using a browser (e.g. Chrome, Explorer, Safari, Firefox), these programs have tools to refuse and disable the collection of some browsing data, including the ability for you to browse anonymously. We will always respect your right to do so. Important: by doing this, some areas of the website may not work properly.
(ii) On our website. In addition to browser options, we also offer preference settings to manage how we collect your browsing data (i.e., preventing collection for marketing or analytics purposes). You can also do this directly from our Cookie Notice.
(iii) By e-mail. You may contact us at privacidade@eurofarma.com.br and request data processing restrictions. We will appraise your requests and, if legitimate, act upon them.
If we are using Personal Data for a purpose to which You do not agree, You may object to it.
In our day-to-day business, we may use legal bases that do not depend on your consent, such as legitimate interest. This is standard and we always exercise such right responsibly and in your best interest, but if You believe that such a purpose impacts Your rights, please email us at privacidade@eurofarma.com.br and we will stop using Your Personal Data for that purpose. Please note that, in some cases, we may demonstrate that we have legitimate reasons to keep processing your Personal Data, but we will always justify this to You in the best manner possible.
After having given consent to our processing of your Personal Data, you may change your mind.
You may revoke your consent by e-mailing Us at privacidade@eurofarma.com.br. At the time, we will also inform you of any consequences of revoking your consent (i.e., restrictions on the use of a certain service that depends on your consent).
If you want a copy of all your Personal Data or portability, You may request it from Us.
Email us at privacidade@eurofarma.com.br and we will provide such Personal Data in a format compatible with any computer, to You or to any third party You request. As a security measure, we may request additional Personal Data to verify your identity and prevent fraud.

We may need to ask specific information from You to help us confirm your identity and to ensure your right to access your Personal Data (or to exercise your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who is not entitled to receive it. We may also contact you for further information regarding your request in order to expedite our response.

We strive to respond to all legitimate requests within 10 business days. Occasionally, it may take longer than 10 business days if your request is particularly complex or if You have made multiple requests. In this case, we will notify You and keep You updated on the progress of Your request.

Should You have any questions on these issues and how You can exercise these rights, please contact us at privacidade@eurofarma.com.br.

6. How long will your Personal Data be stored?

We will only keep your Personal Data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of complying with any legal (such as the Brazilian Civil Rights Framework for the Internet to store access logs for 6 months), contractual, accountability, or competent authorities' request obligations.

To determine the appropriate retention period for Personal Data, we consider the nature of the Personal Data, the purpose of its processing and applicable legal requirements.

7. How do we protect your Data?

We take technical, administrative, and organizational measures to protect your Personal Data from loss, unauthorized use, or other misuse. Data is stored in a secure operating environment that is not accessible to the public.

In order to ensure the security of your Personal Data on our Services, we adopt the best available information security practices, including:

access to the database restricted to companies and authorized professionals;
end-to-end encryption;
monitoring the accesses and actions performed in relation to Personal Data;
defining a clear distinction of roles and competencies regarding the categories of people responsible for or involved in the systems;
the regular internal and external auditing of Personal Data protection; and
the adoption of preventive procedures against information security incidents

We strive to protect the privacy of your account and other Personal Data we maintain about You in our records, but unfortunately we cannot guarantee complete security. Unauthorized account entry or use, hardware or software failure, and other factors may compromise the security of your Personal Data at any time, so please help us maintain a secure environment for everyone. In addition to adopting the best security practices with respect to your account and your data, if You identify or become aware of anything that compromises the security of your data, please contact us.

8. How to contact us?

If You believe that Your Personal Data has been used in a manner inconsistent with this Privacy Policy or with Your choices as a data subject, or if You have other questions, comments or suggestions regarding this Policy, You may contact our team at privacidade@eurofarma.com.br.

9. Changes to the Privacy Policy

As we are actively striving to improve our Services, this Privacy Policy may be updated. Therefore, we recommend that You periodically visit this page to be aware of any changes. If material changes are made that require a new consent from You, we will post such update and ask You for a new consent.

Latest change: October 27, 2020.