Privacy Policy for Healthcare Professionals

In accordance with the provisions of the personal data protection regulations, FERRER INTERNACIONAL, S.A. (hereinafter, "FERRER") with NIF A08041162 and address at Avda. Diagonal no. 549, 5ª Planta de 08029 Barcelona, will process your professional data as the data controller whose data protection officer can be contacted through the dpo@ferrer.com mailbox. 

At FERRER we cover all the links in the value chain of medicines and pharmaceutical products, from research and development, to distribution and marketing, including purchasing and supply.

In our aim to provide significant and differential value to people suffering from serious ailments, at Ferrer we have defined a clear global strategy aimed at developing a portfolio of innovative products/services capable of transforming the lives of patients suffering from these diseases.

You will be able to receive information about these products or services, as well as the pathologies associated with them, marketed by the different companies of the FERRER group in Spain.

Purposes of processing, legal basis and data communications. 

FERRER will process your personal data for the purposes indicated below, relating them to their corresponding legal basis, in accordance with the provisions of Article 6 of 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of personal data and on the free movement of such data, and by which Directive 95/46/EC (hereinafter, "GDPR") is repealed: 

• To promote and provide you with information about the products and services of FERRER or the companies of the FERRER group through remote visits.

• Share with you, by any means, including electronic means, scientific and commercial information of your delegate, related to your specialty or professional interests. 

• To send you commercial communications through electronic channels about products and services of FERRER or the companies of the FERRER group with information of interest.

• If you have requested it, send you scientific information in response to your queries. FERRER will answer you through the means you have used to contact us and if you request it, we will send it to you by electronic means. 

The basis that legitimises the processing of your personal data for these purposes is your express consent (Art. 6 (a) GDPR). Inform you that you may revoke this consent at any time without the withdrawal affecting the processing carried out prior to the withdrawal. 

• For those cases in which FERRER has a contractual relationship with you, such as, for example, if you are a pharmacist; Your personal data will be processed to manage contractual or commercial operations for the sale of the products and services contracted. 

The legal basis that enables FERRER to process your personal data is the execution of the contract for the marketing or sale of FERRER products (art. 6 section b) of the GDPR), and the processing of your data is necessary for the execution of this contract. In this case, your data may be communicated to those third parties that are necessary to ensure the proper execution of the aforementioned contract, for example, courier and transport companies.  

• In addition, in accordance with the provisions of Article 21.2 of Law 34/2002, of 11 July, on information society services and electronic commerce, we may send you commercial communications referring to FERRER products or services that are similar to those that were initially contracted by you. In any case, you have the right to object to this sending both in each commercial communication you receive or by sending your request to lopd@ferrer.com. 

The legal basis that will legitimise the processing of your data for this purpose is FERRER's legitimate interest (art. 6 f) of the GDPR) in publicising products or services that may be of interest to you because they are similar or similar to those you previously contracted. 

• Send you urgent medical information about our products and services in those cases in which due to new knowledge and advances in research or reports we must send you this information to ensure the proper use of them and guarantee that they are used safely.

• Comply with legal or ethical obligations, for example, in terms of pharmacovigilance or delivery of medical samples, among others. In the case of complying with pharmacovigilance or surveillance purposes of medical devices, your personal data will be processed when relevant to document and correctly manage the adverse reaction reported. In these cases, you can be contacted by FERRER in order to follow up on the report. 

• The processing of your data for the aforementioned purposes is carried out on the basis of the legal obligation that FERRER may have, as the case may be, as a manufacturer, authorised marketing representative and/or distributor of pharmaceutical and healthcare products. (Art. 6 (c) GDPR).

  Likewise, in relation to this processing, your personal data may be communicated to the competent authorities or entities to comply with the obligations of pharmacovigilance or surveillance of medical devices. Your data may also be disclosed to third parties that we are contractually obliged to communicate, such as the licensor of the medicine, the holder of the marketing authorisation of the medicine or the manufacturer of the medical device. 

  • To promote and show you FERRER's new products and/or services, as well as the advances made in them by carrying out face-to-face medical visits in which we will go to the medical centre and/or facilities where you carry out your professional medical activity. To do this, we may contact you prior to the visit to organise it or come directly to your facilities. 

  The legal basis that legitimises this processing of your professional contact data is the legitimate interest (art. 6 f) of the GDPR) of FERRER as it considers that as a healthcare professional it may be in your interest to know the new features and improvements of FERRER's products and/or services in order to help you recommend and/or prescribe them to your patients, Your interests as an interested party will not be harmed at any time, since it will allow you to carry out your professional activity with more knowledge of the existing products on the market and have sufficient criteria to recommend and/or prescribe those products that may be of most interest or benefit to your patients in response to their needs and pathologies. 

  • Send you surveys about the products, services or events of FERRER or the companies of the FERRER group. As a healthcare professional, it is very useful for us to know your opinion and that of your patients, related to our products, services, as well as  the interactions we have with you. FERRER may contact you as a result of your answers and recommendations in order to improve your experience after the relationship with FERRER.

  This processing is legitimised by FERRER's legitimate interest (art. 6 f) of the GDPR, considering that the knowledge that can be acquired after receiving the results of the survey may benefit society in general, since it will allow FERRER to modify and/or improve the products and services for which it has been requested. In no case, we understand that your interests may be harmed by receiving this type of survey, rather you will be able to see an improvement in your patients thanks to the comments reported in them. 

  • Propose and manage professional interactions such as the provision of services, participation in congresses and scientific or training activities, medical research projects or market research studies. 

  In order to carry out this processing, FERRER has considered, after the relevant analysis and weighing of your interests with those of FERRER as data controllers, the existence of a legitimate interest (art. 6 f) of the GDPR) by considering that your interests as a data subject are not harmed by carrying out such processing but rather that it may be of direct benefit to your professional profile. as well as to provide you with medical knowledge that may be useful and interesting for the exercise of your functions and the exercise of the health profession developed. In this sense, FERRER is interested in processing your data in order to have the possibility of maintaining contact with professionals like you, in order to detect new pharmacological needs, share knowledge, make advances in the market, etc.  

  Where appropriate, your personal data may be communicated to third parties in order to be able to correctly manage the proposed professional interactions, organise your participation in congresses and scientific activities or send them to those entities or third parties that organise training activities or medical research. In the event that we propose you to participate in a market research study, we may work with independent market research agencies who will carry out the aforementioned studies. In this case, we may share your identifying and contact information with these market research agencies so that they can carry out the contracted studies. 

   

  We inform you that, in the event that you do not want FERRER to contact you to offer you these opportunities, you do not want them to visit you at your workplace to inform you about our products and services, you do not want to receive surveys about our products and/or services, you can send your request at any time to lopd@ferrer.com informing us that you do not want FERRER to process your personal data for the corresponding purpose. On the other hand, if you would like more information about the weighting and analysis carried out by FERRER in relation to the assessment of the existence of our legitimate interest, you can send your request to dpo@ferrer.com. 

   

  In relation to the  above, in the event that you agree to participate in any of the proposed activities, related to prescription medicines, FERRER is obliged to publish the value transfers made, in accordance with the provisions of article 18 of the Code of Good Practices of the Pharmaceutical Industry issued by FarmaIndustria (National Business Association of the Pharmaceutical Industry). as well as to carry out as many activities as necessary to be able to demonstrate the proposal of these activities, such as, for example, carrying out an attendance control of the training given. This information will be published individually by each category and will be included in a report accessible through the www.ferrer.com website, in order to comply with Ferrer's obligations to issue transparency reports without your consent being necessary, in consideration of the legitimate interest (art. 6 f) of the GDPR) that, according to the criteria of the Spanish Data Protection Agency, companies adhering to the FarmaIndustria Code are held.

  In general and in addition to the communications expressly detailed in each of the purposes, in relation to the communications of your personal data, we inform you that your personal data will not be communicated to third parties, except for compliance with legal obligations that correspond in each case. Notwithstanding the foregoing, your personal data may be communicated to the companies of the Ferrer Group (Global Presence | Ferrer) if it is necessary to comply with the Group's internal administrative purposes. 

  Likewise, inform you that your personal data may be accessed by third parties acting on behalf of FERRER, provided that such access and data processing is essential for the provision of a service contracted by FERRER. Under this scenario, FERRER will in any case sign the corresponding data processor contract with each of these third parties, which will process your data exclusively for the purposes that FERRER determines in each case following our instructions and never for its own purposes.

   

  Source of your data

  In the event that you have not directly provided us with your personal data, FERRER may have accessed them due to the communication made by IQVIA INFORMATION S.A.U. (hereinafter, "IQVIA"), a world leader in the provision of services for the combined industries of health information technology and clinical research. IQVIA sends us the data of health professionals, specifically, identification and contact, as well as the medical specialty that corresponds to you in order to be able to contact you and offer you or carry out our commercial activity, such as, for example, visiting you in person at your workplace or at the centers where you are carrying out your activity. 

   

  Retention of your data

  With regard to data that is processed on the basis of consent, such as for sending commercial communications or responding to your requests, we will keep them as long as you do not withdraw it from us or request its deletion. Where appropriate, your data will be duly blocked for a period of three years in order to comply with the obligations arising from data protection regulations, specifically, Organic Law 3/2018, of 5 December, on data protection and guarantee of digital rights. 

  As for the processing carried out based on FERRER's legitimate interest, we will process them as long as you do not exercise your right to object. Where appropriate, FERRER will stop processing your data in response to your request unless, in view of the specific case, it could lead to arguing the existence of compelling legitimate reasons for having to continue processing the data and thus limiting your right. 

  In the case of transfers of value, your personal data will be published for a minimum period of 3 years from the date of publication or for the period that, where appropriate, is legally established. The documentation that proves the transfers of value will be kept, duly blocked, for a period of 5 years from the end of the maximum period for publication of the publication or, failing that, the legally established period.

  In relation to the rest of the processing, as soon as the purpose for which they were processed expires, FERRER may keep them duly blocked in order to be able to make them available to judges and courts, the Public Prosecutor's Office or the competent Public Administrations, in particular to the data protection authorities for the enforcement of possible responsibilities arising from the processing and only for the limitation period of the same. In general, you can obtain more detailed and specific information at a later time, for example, when placing an order or in the case of reporting adverse reactions. 

   

  Rights of the data subject

  As the owner of your data, you can exercise the following rights at any time by clearly indicating the right you wish to exercise by sending an email to the address lopd@ferrer.com. 

  • Access: you will be able to obtain confirmation if FERRER processes your personal data, as well as check if your personal data is included in FERRER's files.

  • Rectification: you may modify your personal data when they are inaccurate or complete those that are incomplete.

  • Erasure: you may request the deletion of your personal data when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

  • Objection: You may request that your personal data not be processed. FERRER will stop processing the data, except for compelling legitimate reasons, or the exercise or defence of possible claims.

  • Limitation of processing: you may request the limitation of the processing of your data in the following cases:

    • While the challenge to the accuracy of your data is verified;

    • When the processing is unlawful and you object to the erasure of your data and request the restriction of its use;

    • When FERRER does not need to process your data, but you need it for the exercise or defence of claims;

    • When you have objected to the processing of your data for the fulfilment of a mission in the public interest or for the satisfaction of a legitimate interest, while it is verified whether the legitimate grounds for the processing override yours.

  • Portability: you will be able to receive, in electronic format, the personal data that you have provided us with and those that have been obtained from your contractual relationship with FERRER, as well as to transmit them to another entity.

  • Withdrawal of consent: you may withdraw your consent at any time without affecting the lawfulness of the processing based on consent prior to its withdrawal.

  The exercise of these rights will be free of charge provided that they are not exercised in a manifestly unfounded or excessive manner. 

  Finally, in the event that you consider that FERRER has not processed your data in accordance with current legislation, you have the right to file a complaint with the corresponding supervisory authority, which in Spain is the Spanish Data Protection Agency (www.aepd.es).  

  Finally, and as a sign of FERRER's commitment to people's privacy, we would like to inform you that we are adhered to the Code of Conduct regulating the processing of personal data in the field of clinical trials and other clinical research and pharmacovigilance, promoted by Farmaindustria and approved by the Spanish Data Protection Agency. 

  If you have any questions regarding the processing of your personal data, you can contact our Data Protection Officer at the following email address: dpo@ferrer.com.  

   

  Version: July 2023