Privacy policy

 

On this page

  1. Introduction
  2. Who is the Data Controller?
  3. What kind of information do we collect?
  4. How do we collect your information
  5. For what purposes and legal basis do we process your personal data?
  6. How long will your data be kept for?
  7. Will your data be disclosed to other recipients?
  8. Will your data be sent to a country outside Switzerland or EU?
  9. How do we protect your personal data?
  10. What are your rights?
  11. Changes to this Privacy Policy
  12. Who can you contact at TRB?

 

1. Introduction

Your privacy is important to us, and we are committed to the protection of your privacy in your interaction with us. TRB Chemedica International S.A. (collectively, “TRB”, “we”, “us” or “our”) respects the importance of protecting personal data collected from customers and other users of services. By submitting information to TRB you consent to practices described in this policy, which aim to maintain the security, integrity and privacy of any information in accordance with the EU General Data Protection Regulation 2016/679 (GDPR) and the revised Federal Act on Data Protection (FADP). If you are less than 18 years of age, then you must first seek the consent of your parent or guardian prior to submitting any personal data.

This privacy policy describes how TRB collects and uses the personal data you provide to us. It will also describe the choices available to you regarding our use of your personal data as well as how you can access, update and delete this information.

If you have questions or comments about our administration of your personal data, please contact us at dpo@trbchemedica.com.

2. Who is the Data Controller?

Unless we inform you otherwise in certain cases, the controller of data processings is:

TRB CHEMEDICA INTERNATIONAL SA
Route des Jeunes 33bis
1227 Carouge GE
Switzerland

Email: dpo@trbchemedica.com

3. What kind of information do we collect?

In general, you are not required to submit any personal information to TRB, but we will require you to provide certain personal information in order for you to receive additional information about our services and offerings. TRB will also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as newsletters – if available –, you will be able to unsubscribe at any time.

To follow the objectives of TRB, to provide our services and offerings to TRB customers and to all other users we must process personal data. The type of data we collect depends on how you use TRB services and offerings.

a) Information and content you provide: we collect the content, communications and other information you provide when you visit our website and/or use TRB services and offerings, including one of our digital services and create and share content to message or communicate with TRB. This can include: personally identifiable information, such as name and surname, physical and email address, gender, etc.

b) Usage: we collect information about how you visit our website and/or use TRB services and offerings, such as the actions you take and the time, frequency and duration of your activities. For example information collected by website cookies (please refer to the Cookie Policy) on our website.

4. How do we collect your information

TRB may collect your personal data in the following ways:

a) Directly: from your written or verbal input such us online forms with input fields and checkboxes, letters and email correspondences, phone calls, phone messages, voice messages, documents delivered in paper and digital versions on various carriers or means of transfer;

b) Indirectly:

  • Automatically through digital technologies including online tracking, as by website cookies, by smart devices or by combining data sets, by collecting data from a browser or device, or by using algorithms and statistics to analyze the variety of data such as records of behavior, usage, location;
  • Partners: TRB might use applications and services developed and held by our partners, e.g. suppliers to collect your personal data, contact details and statistical information about how you use their services including your settings and preferences.

5. For what purposes and legal basis do we process your personal data?

TRB may use your personal data for the following purposes and legal basis:

a) Marketing: to provide you with information about the status, obligations, services and offerings. Furthermore, to administer all of TRB services and offerings, notifications and reminders, including troubleshooting, data analysis, testing, statistical and survey purposes.
Legal basis: legitimate interest

b) Website browsing: for activities necessary for the functioning of the website and the provision of navigation services on the platform. Furthermore, to help enhance, evaluate, develop, and create TRB websites.
Legal basis: legitimate interest

c) Answer to your contact requests: to provide a feedback on your request when you contact us via email, telephone or the contact form.
Legal basis: performance of contract

d) Legal requests: information we receive about you can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigation of possible violations of our terms or policies, or otherwise to prevent harm.
Legal basis: legitimate interest

6. How long will your data be kept for?

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 unauthorized 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.

7. Will your data be disclosed to other recipients?

When you share and communicate personal data provided will be communicated both internally within TRB and externally. However, we do not share personal information with unaffiliated third parties, except as necessary for our legitimate professional business needs, to carry out your requests, and/or as required or permitted by law.

This would include:

  • Our service providers: We transfer your personal information to our third party service providers, such as our (IT-) systems providers, our hosting providers, license partners or other companies with whom we collaborate for promotional and research purposes, marketing communications and in order to provide you with product and service updates. TRB works with such providers so they can process your personal information on our behalf.
    TRB’s subsidiaries and affiliates.
  • Courts, tribunals, law enforcement or regulatory bodies: TRB will disclose personal information in order to respond to requests of courts, tribunals, government or law enforcement (e.g. reporting adverse events for materiovigilance and/or pharmacovigilance), court orders or other proceeding, or in case of audits or investigations regarding complaints or security threats.
  • Disclosure on a confidential basis to our advisers. For example, to lawyers for the purposes of seeking legal advice or to our accountants and consultants.

8. Will your data be sent to a country outside Switzerland or EU?

We process and store your personal data mostly in Switzerland, sometimes also in the European Economic Area (EEA). However, in certain cases, we may disclose personal data to service providers and other recipients located or otherwise processing personal data outside this area. In general, TRB transfers your personal data only to countries that ensure an adequate level of data protection.

Some of the countries may not have laws that protect your personal data to the same extent as in Switzerland or the EEA. If we transfer your personal data to such a country and to the extent required by applicable law, we will ensure the protection of your personal data in an appropriate manner, e.g. by implementing the necessary legal, operational and technical measures before such transfers.

One means of ensuring adequate data protection is, for example, the conclusion of data transfer contracts with the recipients of your personal data in third countries to ensure the necessary data protection. These include contracts that have been approved, issued or recognized by the European Commission and/or the Swiss Federal Data Protection and Information Commissioner, so-called standard contractual clauses. Please note that such contractual arrangements can partially compensate for weaker or missing legal protection, but cannot completely exclude all risks (e.g. from government access abroad).

In exceptional cases, the transfer to countries without adequate protection may also be permissible in other cases, e.g. based on consent, in connection with legal proceedings abroad or if the transfer is necessary for the performance of a contract.

9. How do we protect your personal data?

We have put in place appropriate security measures to hold your personal information securely in electronic and physical form in order to protect your data from unauthorized access, improper use or disclosure, unauthorized modification, unlawful destruction or accidental loss.

10. What are your rights?

If we process your personal data, you have the following rights:

  • Information: you have the right to be informed about what personal information we have about you and how we process it.
  • Access and correction: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information.
  • Object to processing: you have the right to object to us processing your personal information if we are not entitled to use it anymore.
    Data Portability: where we process your personal data in an automated manner on the basis of your consent, or where such processing is necessary for entering into or performing our obligations under a contract with you, you may have the right to request your personal data be transferred to you.
  • Other Rights: in addition, you may request the deletion of your data if we are keeping it too long, request to restrict the processing in certain circumstances, you can withdraw your consent where we obtained it to process personal data (without this withdrawal affecting the lawfulness of any processing that took place prior to the withdrawal).

You can exercise the rights set out above by sending an email to dpo@trbchemedica.com.

11. Changes to this Privacy Policy

TRB reserves itself the right to modify this Privacy Policy at any time. Therefore, before using the Site or related resources (e-mail, telephone, social account, etc.), it is your responsibility to verify the content of the current information. In order to facilitate such verification, this policy will contain an indication of the date of update.

12. Who can you contact?

Lastly, you have the right to lodge a complaint with the competent data protection authority. In Switzerland the competent data protection authority is the Swiss Federal Data Protection and Information Commissioner.