Privacy Policy and
Personal Data Protection - REPI
REPI and
its owner and manager – ActOne, S.A., undertakes to maintain the privacy and the confidentiality of
all the information provided by the User. This Privacy Policy establishes the
measures adopted by REPI and its owner and manager – ActOne,
S.A., regarding the Personal Data collected directly from the User
(Pharmaceutical Industry Representative or Healthcare Professional) and/or
through the website www.repi.pt,
in accordance with the General Data Protection Regulation and other applicable
national and international legislation. The expression "Personal
Data" refers to all the personal information provided by the User
(Pharmaceutical Industry Representative or Healthcare Professional), such as
name, profession, date of birth, telephone number, address or e-mail address.
It may be conferred to the user the definition of Pharmaceutical Industry
Representative or Healthcare Professional. Throughout this document any
reference to REPI is and it will always be extended to its owner and
manager – ActOne, S.A.
General Privacy Rules and
Personal Data Processing
The
Personal Data provided will be used by REPI in the provision of the
requested service. To the User (Pharmaceutical Industry Representative or
Healthcare Professional) it will only be requested the Personal Data which is
strictly necessary and relevant to the provision of the service. The
information will be sent by REPI to the address or to the electronic mail provided by the User
(Pharmaceutical Industry Representative or Healthcare Professional).
ActOne, S.A. respects all the legal
requirements regarding to the personal data processing which is made available
by all those who engage with the Company. Those personal data processing is in
fully accordance with the General Data Protection Regulation (Regulation EU
2016/679 of April 27, 2016) and other legal impositions.
The
provision of personal data, by the user, on this platform, implies the
knowledge and the acceptance of the conditions contained in this Privacy
Policy.
Identity and contacts of
the data controller
The entity responsible
for the collection and processing of personal data is ActOne, S.A., since
it is the person who determines the purposes and means of the processing of the
personal data which are provided
to him.
The
contacts of ActOne, S.A. are: e-mail geral@actone.pt, or ActOne S.A., Alfrapark, Estrada
de Alfragide, nº 67, Piso
F, Piso 1, Sul, 2610-008 Amadora.
What kind of personal data
are collected
ActOne,
S.A. collects and processes the personal data necessary to provide services
related to the REPI platform,
such as the name, professional name, professional identification number,
e-mail, telephone contact, date of birth, gender, starting year of
work, correspondence address, specialty, professional domicile, country or
nationality and geographical information.
How to collect your personal data
The
personal data are provided by the owner of the same, after their registration
in the platform.
Purposes of the processing
of personal data
The
personal data collected are intended to the service provision requested by the
REPI platform which is to create a personal account on a multichannel
communication platform with representative professionals of the pharmaceutical
industry. REPI may also send information about new products and/or
services related with communication and marketing; regular updates that REPI considers
of interest to the User (Pharmaceutical Industry Representative or Healthcare
Professional).
How long will the personal
data be stored
The data
will be kept for as long as the data subject are professionally active and as
long as the data subject does not proceed with the cancellation of the user
account.
How to access, rectify or
oppose the processing of your personal data
In
accordance with Regulation (EU) 2016/679 of 27 April 2016, the data subject has
the right to access, update, rectify or request the erasure of their personal
data.
To this
end, the User (Pharmaceutical Industry Representative or Healthcare Professional)
must contact ActOne,
S.A. in writing through the e-mail privacy@actone.pt or to the
address indicated in the contacts provided in this Privacy Policy. Regarding
the Pharmaceutical Industry Representative, this process will be obviously
focused on the Pharmaceutical Company which is the employer of the
Pharmaceutical Industry Representative in question.
How to withdraw my consent
The data
subject must contact ActOne, S.A. in writing through the email privacy@actone.pt or
to the address indicated in the contacts provided in this Privacy Policy.
Claims
Under the
terms of the General Data Protection Regulation, the data subject has the right
to submit any complaint to the National Data Protection Commission, without
prejudice to any other administrative or extrajudicial remedy.
Security, Privacy and
Confidentiality
REPI has
adopted, regarding the personal data, the adequate security measures for the
protection of personal data and has installed all the means and technical
measures at its disposal to prevent loss, misuse, alteration, unauthorized
access and theft of personal data provided by User (Pharmaceutical Industry
Representative or Healthcare Professional). However, any User (Pharmaceutical
Industry Representative or Healthcare Professional) should be aware that the
data transmissions on the Internet only benefit from a relative technical
reliability and there is a risk that unauthorized third parties may access the
personal data of the registered Users (Pharmaceutical Industry Representative
or Healthcare Professional).
Although REPI has taken the necessary
measures to ensure the safety of its Users (Pharmaceutical Industry
Representative or Healthcare Professional), it is the responsibility of each
User (Pharmaceutical Industry Representative or Healthcare Professional) to
adopt measures to maintain the confidentiality of their access password. It is
also the duty of the User (Pharmaceutical Industry Representative or Healthcare
Professional) to ensure that all the information made available by the REPI system is correct, true and
latest. Without prejudice of the verification made by REPI, it is the User's responsibility
(Pharmaceutical Industry Representative or Healthcare Professional) all the
information that the same uploads and provides to the system.
Any user
(Pharmaceutical Industry Representative or Healthcare Professional) can freely
navigate through the platform www.repi.pt,
not being collected any personal data. Personal data collected by REPI are provided exclusively and
voluntarily by the users (Pharmaceutical Industry Representative or Healthcare
Professional) of this website.
To protect
and to ensure the integrity of our users’ information (Pharmaceutical Industry
Representative or Healthcare Professional), REPI uses industry-leading security technology
for production, communication and storage. All personal and professional data
received on our systems is automatically processed and stored in a secure and
credible way due to the fact that it had being created all the possible
technical conditions to avoid any misuse.
All
communications (text, sound and video) made with REPI or performed between the users
(Pharmaceutical Industry Representative or Healthcare Professional) are
completely encrypted and cannot be accessed by third parties due to the HTTPS
security system. When the User (Pharmaceutical Industry Representative or
Healthcare Professional) access REPI or the reserved area, the user is
accessing a secure and confidential domain where the communications are
performed under the HTTPS protocol which ensures that the information exchanged
between the REPI server
and the user’s computers (PCs, Smartphones or Tablets) is encrypted and it is
not deciphered by possible attackers. All the website security and the processes
have been audited by an external certified entity (Digicert).
REPI in
its video call functionality does not have any type of software or system that
would record the interaction of the two parties because it is not the REPI's policy the recording of their
video calls users (Pharmaceutical Industry Representative or Healthcare
Professional).
Collection of anonymous
data through the website www.repi.pt
In addition
to the collection of data by the above means, REPI uses technology
that allows the collection of information about the Users (Pharmaceutical
Industry Representative or Healthcare Professional) from the website www.repi.pt. For example, the
website server automatically collects the pages visited, the User's IP address
(Pharmaceutical Industry Representative or Healthcare Professional) and the web
browser that it is used. This technology does not allow the personal
identification of the User (Pharmaceutical Industry Representative or
Healthcare Professional), nor it is its purpose, serving only for statistical
purposes and for the improvement of our services.
Our website
contains links to other websites. Technology may also be used to monitor how
often these links are used and which websites are the most visited. Again, this
technology does not allow the personal identification of the User
(Pharmaceutical Industry Representative or Healthcare Professional) – serving
only for statistical purposes and for the improvement of our services.
Cookies Policy
In order to
collect the information referred to in the previous paragraph, it may be used
temporary cookies which will remain in the cookies file of the User's web
browser (Pharmaceutical Industry Representative or Healthcare Professional)
until it is closed. Cookies by themselves do not serve to identify the User
(Pharmaceutical Industry Representative or Healthcare Professional). The cookie
is a small piece of information sent to the User's server (Healthcare
Professional or Representative of the Pharmaceutical Industry) and stored on the
user’s computer’s hard drive, causing no damage to it. The User (Pharmaceutical
Industry Representative or Healthcare Professional) may program the web browser
in order to be notified whenever receives a cookie, so that he can choose to
accept or reject it.
We also use
the User's IP address (Pharmaceutical Industry Representative or Healthcare
Professional) to help to diagnose problems with the User’s server and to
administrate our website conveniently, keeping in mind the continued
improvement of our services. The IP address is a numeric code that identifies a
computer on the network, or in this case, in the Internet. The User's IP
address (Pharmaceutical Industry Representative or Healthcare Professional) is
also used to collect geographic information. We may also conduct IP surveys to
determine from which domain the User (Pharmaceutical Industry Representative or
Healthcare Professional) set out to better gauge the User's geographical data
(Pharmaceutical Industry Representative or Healthcare Professional).
Disclosure of Personal
Data
REPI does
not disclose, sell or distribute the Personal Data collected to third parties
that have no relation to the provision of the service, unless otherwise stated
and in the following situations: To provide to the User (Pharmaceutical
Industry Representative or Healthcare Professional) the requested information
or products, the Personal Data provided may be transferred or shared with other
companies belonging to the REPI representative group or with third parties acting on behalf of
the REPI for
further processing, in accordance with the purposes of which the data was
collected, or only in the cases authorized by the User (Pharmaceutical Industry
Representative or Healthcare Professional). For example, sometimes a third party
may have access to the Personal Data to support information technology or to
manage correspondence on behalf of REPI.
In cases
which the User (Pharmaceutical Industry Representative or Healthcare
Professional) has consented, the User’s Personal Data may be shared with other
companies belonging to the same REPI representative group or the same data can
be disclosed to other companies that may contact the User about their products
or services that can be of the User’s interest.
REPI may
share, transfer or disclose information from its database and server logs to
comply with any governmental, judicial, administrative order, or to interact
with anti-fraud databases, or to protect the user's vital interests
(Pharmaceutical Industry Representative or Healthcare Professional), or to
protect the security or integrity of our databases or the website, or to take
action against legal liability, or in the case of a sale, merger,
reorganization, dissolution or other event related to REPI. REPI will inform the User (Pharmaceutical
Industry Representative or Healthcare Professional) in case of transfer or
disclosure of the data, in accordance with the legal requirements.
When
appropriate, before disclosing Personal Data to a third party, REPI will contractually establish
with that third party the obligation to take all the necessary measures to
protect the received data and to comply with all the applicable legislation.
Links to other sites
The website
www.repi.pt may contain links
to websites which are not operated by REPI. These links are made available only for
reference and convenience of the User (Pharmaceutical Industry Representative
or Healthcare Professional) and it does not imply any endorsement or acceptance
of the activities of those third parties or any association with those
operators. REPI does
not control these websites and is not responsible for its data and privacy
policy. In this case, we recommend that the User (Pharmaceutical Industry
Representative or Healthcare Professional) looks for information about the
Privacy Policy before using any site or providing any Personal Data.
Transfer of data to and
from abroad
If the
User (Pharmaceutical Industry Representative or Healthcare Professional) is in
a different country from the one where the REPI's servers are located, the communications
may result in a trans-border information transfer. In such cases, ActOne, S.A., as the entity responsible
for the processing, ensures that any personal data transfer, on the terms set
forth, it will only be performed if the conditions established by the General
Regulation Data Protection are respected.
By
visiting our website and communicating with REPI by electronic means, the User
(Pharmaceutical Industry Representative or Healthcare Professional) authorizes
the processing and transfer of the Personal Data as set forth in this Privacy
Policy.
Applicable Law
This
Privacy Policy is an integral part of the Terms and Uses of the site www.repi.pt.
In case of controversy or claim of any nature related to this website, it will
be applicable the Portuguese law, regardless of any laws conflict applicable.
All the legal actions or proceedings arising from or related to this Privacy
Policy, its validity, application, compliance or non-compliance, or the subject
matter of this Privacy Policy, shall be submitted to the Portuguese courts, and
the User (Pharmaceutical Industry Representative or Healthcare Professional)
hereby consents to and irrevocably submits to the jurisdiction of these courts
in the cases indicated. Notwithstanding the foregoing, REPI reserves the right to bring a
competent action in any jurisdiction in which the breach of this Privacy Policy
is found.
Notification in case of
changes to the Privacy Policy
We are
constantly improving our products and services and adding new features to the
website www.repi.pt, as well as to the existing services and
products. Due to these constant changes and improvements, like the
modifications in the applicable legal regime and in the evolution of the
technology itself, our practices regarding data processing may also change. If
it occurs any amendment to this Privacy Policy, REPI will promptly notify the User
(Pharmaceutical Industry Representative or Healthcare Professional), as well as
the responsible local authority, in cases required by law.
When you
choose to purchase the products or services from www.repi.pt or
receive additional information from REPI, you may be asked to provide the following
information: name, address, e-mail address, mobile phone, data proving the
profession and/or educational qualifications. You will also be asked for
geographical information so that REPI can provide you with a more personalized
service. The information provided will be archived in the REPI databases, either manually or
by electronic means. REPI may complement the information provided by the User
(Pharmaceutical Industry Representative or Healthcare Professional) with the
information provided by third parties, such as, for example, if an incorrect
postal code is provided, REPI may use third parties to correct this information.
Comments
REPI appreciates
that for any comments about this Privacy Policy or any other question, the User
(Pharmaceutical Industry Representative or Healthcare Professional) directly
contact REPI through the electronic mail address geral@repi.pt or in
writing to the headquarters address and/or ActOne, the owner and manager
of REPI, through the contacts indicated below: (WHICH ARE ALREADY THERE ON
THE WEBSITE)
For more
information, see ActOne's Privacy Policy.
(http://actone.pt/pt_politica_de_privacidade.html)
Last updated: May 14, 2018