Condor Pharma develops web and mobile software primarily for medical
and pharma applications but also for other business applications.
Condor Pharma is committed to the protection of personal data in
compliance with the General Data Protection Regulation (GDPR) and any
similar rules or guidance that are in force in the UK, including the
Data Protection Act 1998, 2018 or any future related legislation.
2. PURPOSE OF THIS PRIVACY POLICY
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This Privacy Policy aims to make you fully aware of how and why we are
using your data by giving you information on how Condor Pharma
collects and processes your personal data through your use of this
website or our mobile apps and services, including any data you may
provide through this website or mobile apps when you sign up to our
services, visit our web pages or contact us.
Not all of our mobile applications collect personal data and some apps
will collect none. The individual app listing in the relevant App
store will highlight what data, if any, we collect and then this
policy can be used to see how and why this data is used.
This website and our mobile apps and services are primarily intended
for adults and we do not intentionally or knowingly collect data
relating to children.
In this document, we adopt the same definitions as the GDPR, in
particular:
Personal data ‘means any information relating to an identified
or identifiable natural personal (“data subject”); an identifiable
natural person is one who can be identified, directly or indirectly,
in particular by reference to an identifier such as 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’.
Processing ‘means any operation or set of operations which is
performed on personal data or on sets of personal data, whether or not
by automated means, such as collection, recording, organisation,
structuring, storage, adaptation or alteration, retrieval,
consultation, use, disclosure by transmission, dissemination or
otherwise making available, alignment or combination, restriction,
erasure or destruction’.
Controller ‘means the natural or legal person, public
authority, agency or other body which, alone or jointly with others,
determines the purposes and means of the processing of personal data;
where the purposes and means of such processing are determined by
Union or Member State law, the controller or the specific criteria for
its nomination may be provided for by Union or Member State law’.
Processor ‘means a natural or legal person, public authority,
agency or another body, to which the personal data are disclosed,
whether a third party or not. However, public authorities which may
receive personal data in the framework of a particular inquiry in
accordance with Union or Member State law shall not be regarded as
recipients; the processing of those data by those public authorities
shall be in compliance with the applicable data protection rules
according to the purposes of the processing’.
Personal data breach ‘means a breach of security leading to the
accidental or unlawful destruction, loss, alteration, unauthorised
disclosure of, or access to, personal data transmitted, stored or
otherwise processed’.
4. ROLES AND RESPONSIBILITIES
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When Condor Pharma is responsible for your personal data and makes all
the decisions about how your data is processed, we are acting as the
controller. Condor Pharma is also responsible for this website and its
published mobile apps. However, when we are processing your personal
data on behalf of a third party in accordance with their strict
instructions, we are acting as a data processor.
In this Privacy Policy, references to Condor Pharma, "we", "us" or
"our" means Condor Pharma Limited. References to “you”, “your”,
“yours” means you, the data subject. If you have any questions about
this Privacy Policy contact us using the details set out below.
Condor Pharma is a registered business in England.
Full name of legal entity: Condor Pharma Limited
Email address: info@Condor Pharma.com
Registered office: The Bloc, 38 Springfield Way, Anlaby, East
Yorkshire, HU10 6RJ
6. YOUR DUTY TO INFORM US OF CHANGES
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It is important that the personal data we hold about you is accurate
and current. Please keep us informed if your personal data changes
during your relationship with us.
7. THE DATA WE COLLECT ABOUT YOU
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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 may collect, use, store and transfer different kinds of personal
data about you. The type of data we collect about you depends on your
relationship with us. For example, if you are a visitor to our website
or a subscriber to our services. In all cases, we have grouped
together the different kinds of data we may or are likely to collect
from you:
{' '} • Transaction Data which may include details about payments to
and from you and other details of products and services you have
purchased from us. As a policy we do not store full credit cards
details used for making payments through our website - just the last
four digits.
{' '} • Technical Data which may include 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 website and our product.
• Profile Data which may include your username and password,
purchases or orders made by you, your interests, preferences,
feedback and survey responses.
• Usage Data which may include information about how you use our
website, products and services.
• Marketing and Communications Data which may include your
preferences in receiving marketing from us and our third parties and
your communication preferences.
We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data may be derived from
your personal data but is not considered personal data in law as this
data does not directly or indirectly reveal your identity.
For example, we may aggregate your Usage Data to calculate the
percentage of users accessing a specific website or mobile app
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.
8. IF YOU ARE UNABLE TO PROVIDE PERSONAL DATA
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Where we need to collect personal data by law, or under the terms of a
contract we have with you and you fail to provide that data when
requested, we may not be able to perform the contract we have or are
trying to enter into with you (for example, to provide you with goods
or services). In this case, we may have to cancel a product or service
you have with us, but we will notify you if this is the case at the
time.
9. HOW IS YOUR PERSONAL DATA COLLECTED?
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How your personal data is collected will depend on your relationship
with us and we use different methods to collect data from and about
you including through:
{' '} • Direct interactions. You may give us your Identity, Contact
and Financial Data by filling in forms or by corresponding with us
by post, phone, email or otherwise. This includes personal data you
provide when you:
• apply for our products or services
• create an account on our website
• subscribe to our service or publications
• request marketing to be sent to you
• enter a competition, promotion or survey or
• give us some feedback.
• Automated technologies or interactions. As you interact with our
website, we may automatically collect Technical Data about your
equipment, browsing actions and patterns. We collect this personal
data by using cookies, server logs and other similar technologies.
We may also receive Technical Data about you if you visit other
websites employing our cookies. Please see our cookie policy for
further details.
• Third parties or publicly available sources. We may receive
personal data about you from various third parties and public
sources, especially concerning company executives or other
individuals using our services, but also from subscribers and
visitors to our site, as set out below:
• Technical Data from the following parties: (a) analytics providers
such as Google; (b) advertising networks; and (c) search information
and other data providers.
• Contact, Financial and Transaction Data from providers of
technical, payment and delivery services.
• Identity, Contact, Special Category Data or Criminal Data from
data brokers or aggregators.
• Identity and Contact Data from publicly available sources such as
Companies House and the Electoral Register based inside and the EU.
Where we obtain personal data from third party suppliers, we always
ensure that these suppliers are bound to respect data protection laws
and your privacy rights pursuant to their contract with us.
10. HOW WE USE YOUR PERSONAL DATA
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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 we need to perform the contract we are about to enter into
or have entered into with you or with other third parties.
• 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 or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing
your personal data including in relation to sending direct marketing
communications to you via email. You have the right to opt out of
marketing or ask any questions about how we process your personal data
by contacting us at any time.
11. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
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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 register you as a new customer |
(a) Identity
(b) Contact
|
Performance of a contract with you |
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts
due to us)
|
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or Privacy Policy
(b) Asking you to leave a review or take a survey
|
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our
records updated and to study how customers use our
products/services)
|
|
To enable you to partake in a prize draw, competition or
complete a survey
|
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how
customers use our products/services, to develop them and grow
our business)
|
|
To administer and protect our business and this website
(including troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of data)
|
(a) Identity
(b) Contact
(c) Technical
|
(a) Necessary for our legitimate interests (for running our
business, provision of administration and IT services, network
security, to prevent fraud and in the context of a business
reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|
|
To deliver relevant website content and advertisements to you
and measure or understand the effectiveness of the advertising
we serve to you
|
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
|
Necessary for our legitimate interests (to study how customers
use our products/services, to develop them, to grow our
business and to inform our marketing strategy)
|
|
To make suggestions and recommendations to you about goods or
services that may be of interest to you
|
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
|
Necessary for our legitimate interests (to develop our
products/services and grow our business)
|
We strive to provide you with choices regarding certain personal data
uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data
to form a view on what we think you may want or need, or what may be
of interest to you. This is how we decide which products, services and
offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have
requested information from us or purchased services from us or if you
provided us with your details when you entered a competition or
registered for a promotion and, in each case, you have not opted out
of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by
logging into the website and checking or unchecking relevant boxes to
adjust your marketing preferences or by following the opt-out links on
any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not
apply to personal data provided to us as a result of a product/service
purchase, product/service experience or other transactions.
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.
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.
16. DISCLOSURE OF YOUR PERSONAL DATA
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We may have to share your personal data with the parties set out below
for the purposes set out in the table above.
• External Third Parties including:
(a) Service providers acting as processors who provide IT and system
administration services
(b) Professional advisers acting as processors or joint controllers
including lawyers, bankers, auditors and insurers who provide
consultancy, banking, legal, insurance and accounting services
(c) HM Revenue & Customs, regulators and other authorities
acting as processors or joint controllers and who may require
reporting of processing activities in certain circumstances
(d) Our customers or clients (for product personal data) and for all
personal data, other third parties from time to time which may
include market researchers or fraud prevention agencies.
• 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. A list of
our third-party processors is available on request.
17. PERSONAL DATA BREACHES
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Condor Pharma has established a personal data breach response
procedure addressing privacy law requirements related to notification
of personal data breaches.
18. INTERNATIONAL TRANSFER OF PERSONAL DATA
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From time to time, we may share your personal data which involves
transferring it to third parties who may be established 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 the
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.
We will only retain your personal data for as long as necessary to
fulfil the purposes we collected it for, including for the purposes of
satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we
consider the amount, nature, and sensitivity of the personal data, the
potential risk of 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, and the
applicable legal requirements.
By law we have to keep basic information about our customers
(including Contact, Identity, Financial and Transaction Data) for 6
years after they cease being customers for tax and legal purposes.
In some circumstances you can ask us to delete your data: see Request
erasure below for further information. In some circumstances we may
anonymize 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.
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.
Condor Pharma shall keep records of data personal data processing
activities and develop appropriate procedures to ensure it can satisfy
your rights as a data subject where applicable, namely:
Request access to your personal data (commonly known as a “data
subject access request”). This enables you to receive a copy of the
personal data we hold about you and to check that we are lawfully
processing it.
Request correction of the personal data that we hold about you. This
enables you to have any incomplete or inaccurate data we hold about
you corrected, though we may need to verify the accuracy of the new
data you provide to us.
Request erasure of your personal data. The right to erasure enables
you to ask us to delete or remove personal data where there is no good
reason for us continuing to process it. You also have the right to ask
us to delete or remove your personal data where you have successfully
exercised your right to object to processing (see below), where we may
have processed your information unlawfully or where we are required to
erase your personal data to comply with local law. Note, however, that
we may not always be able to comply with your request of erasure for
specific legal reasons which will be notified to you, if applicable,
at the time of your request.
Object to processing of your personal data where we are relying on a
legitimate interest (or those of a third party) and there is something
about your particular situation which makes you want to object to
processing on this ground as you feel it impacts on your fundamental
rights and freedoms. You also have the right to object where we are
processing your personal data for direct marketing purposes. In some
cases, we may demonstrate that we have compelling legitimate grounds
to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables
you to ask us to suspend the processing of your personal data in the
following scenarios: (a) if you want us to establish the data’s
accuracy; (b) where our use of the data is unlawful but you do not
want us to erase it; (c) where you need us to hold the data even if we
no longer require it as you need it to establish, exercise or defend
legal claims; or (d) you have objected to our use of your data but we
need to verify whether we have overriding legitimate grounds to use
it.
Request the transfer of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your
personal data in a structured, commonly used, machine-readable format.
Note that this right only applies to automated information which you
initially provided consent for us to use or where we used the
information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to
process your personal data. However, this will not affect the
lawfulness of any processing carried out before you withdraw your
consent. If you withdraw your consent, we may not be able to provide
certain products or services to you. We will advise you if this is the
case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please
contact us.
22. WHAT WE MIGHT NEED FROM YOU
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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.
23. TIME LIMIT TO RESPOND
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We try to respond to all legitimate requests within one month.
Occasionally it may 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.
24. IF YOU ARE NOT SATISFIED
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You have the right to make a complaint at any time to the Information
Commissioner's Office (ICO), the UK supervisory authority for data
protection issues (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns
before you approach the ICO so please contact us in the first
instance.