At DFE Pharma, we feel responsible to protect the personal data of our customers and business partners and to safeguard your privacy. We believe in the importance of keeping our services transparent, personal and reliable. We invite you to familiarize yourself with this Privacy statement, which we developed to inform you about the way we collect, use and protect your information.

1. About This Privacy Statement

This Privacy statement describes the collection and use of your personal information by DFE Pharma in Europe. It applies whenever one of our websites, mobile apps, social media pages or hardcopy forms redirects you to this statement on www.dfepharma.com. This Privacy statement does not apply to the use of your personal information by websites that are not operated by DFE Pharma.

This Privacy statement may change when prompted by new developments. DFE Pharma advises you to read this Privacy statement regularly in order to stay up to date on any changes. In case of major changes, we endeavour to inform you pro-actively.

This Privacy statement was last updated on 6th August 2020.

2. General information and mandatory information

Information about the responsible party (referred to as the “controller” in the GDPR)

The data processing controller on this website is:

DFE Pharma GmbH & Co KG
Kleverstrasse 187, 
P.O. Box 20 21 20, 
47568 Goch, 

E-mail: pharma@dfepharma.com

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g. names, e-mail addresses, etc.).

Designation of a data protection officer as mandated by law

We have appointed a data protection officer for our company. 

If you have any questions about data privacy at DFE Pharma, feel free to contact him via privacy.info@dfepharma.com.

Information on data transfer to the USA

Among other things, we use tools of companies domiciled in the United States or other from a data protection perspective non-secure non-EU countries. If these tools are active, your personal data may potentially be transferred to these non-EU countries and may be processed there. We must point out that in these countries, a data protection level that is comparable to that in the EU cannot be guaranteed. For instance, U.S. enterprises are under a mandate to release personal data to the security agencies and you as the data subject do not have any litigation options to defend yourself in court. Hence, it cannot be ruled out that U.S. agencies (e.g., the Secret Service) may process, analyze, and permanently archive your personal data for surveillance purposes. We have no control over these processing activities.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

3. How We Use Your Information

The following topics describe how we are using your personal information. Also take a moment to read the MORE INFORMATION section below to find out about:

• Sharing and receiving your information with others
• Storing your information
• Using your information to improve our products and services

3.1 Hosting and Content Delivery Networks (CDN)

External Hosting

This website is hosted by an external service provider (host). Personal data collected on this website are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.

The host is used for the purpose of fulfilling the contract with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online services by a professional provider (Art. 6(1)(f) GDPR). If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 (1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user's end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

Our host will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.

Execution of a contract data processing agreement

In order to guarantee processing in compliance with data protection regulations, we have concluded an order processing contract with our host.

We are using the following host:

Umbraco A/S
Buchwaldsgade 35, 2. sal (second floor),
5000 Odense C
Denmark
Phone: +45 70 26 11 62Email: contact@umbraco.com

Data processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

3.2 Contacting DFE Pharma

Request by e-Mail

If you contact DFE Pharma by email or by completing an online form, we register your query in our database. We also register your name, address, telephone number, email address and all other personal data provided by you.

We only use the data to respond to you, handling your complaints and, after removing all items that relate to you, for improving our products and services.

The processing of these data is based on Art. 6 para. 1 lit. b GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 Para. 1 lit. f GDPR) or on your agreement (Art. 6 Para. 1 lit. a GDPR) if this has been requested.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g. after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions – in particular retention periods.

Request by e-mail or telephone 

If you contact us by e-mail or telephone , your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.

These data are processed on the basis of Art. 6 Sect. 1 lit. b GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6 Sect. 1 lit. f GDPR) or on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR) if it has been obtained.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

3.3 Ordering Samples Online

If you choose to request samples on our website, we use your information to conclude your order, to ship the products and to contact you in relation to your
order. We register your contact details, such as name, address and e-mail address.

We share personal data with third parties only if this is necessary in conjunction with the handling of the contract; for instance, with companies entrusted with the shipment of goods or the financial institution tasked with the processing of payments.

These data are processed on the basis of Art. 6 Sect. 1 lit. b GDPR because your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures

3.4 Request a quote online

If you choose to request a quote in our website, we use your information to generate an accurate quotation based on the products requested, quantity, and country of shipment. We register your contact details, such as name, address,  and e-mail address.

We share personal data with third parties only if this is necessary in conjunction with the handling of the contract; for instance, with companies entrusted with the shipment of goods or the financial institution tasked with the processing of payments.

These data are processed on the basis of Art. 6 Sect. 1 lit. b GDPR because your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures

3.5 Sending advice to yourself (Formulation Tool)

If choose to send the formulation advice to yourself, we will store your email address in our CRM system in order to process the request. You may be contacted by one of our experts to offer formulation support and advice based on your selection. We will not use your email for commercial purposes. Your email will be stored in our database indefinitely unless you revoke your consent.

The data are processed on the basis of the consent obtained (Art. 6 Sect. 1 lit. a GDPR); this consent may be revoked at any time.

3.4 Visiting Our Websites

When you are using our website or apps, we may collect technical information about your device and your interaction with our website and apps:

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them or they are automatically eradicated by your web browser.

In some cases it is possible that third party cookies are stored on your device once you enter our site (third party cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g. cookies for the processing of payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g. the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages.

Cookies, which are required for the performance of electronic communication transactions, or for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TTDSG); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

In the event that third party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.

Server log files

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

• The type and version of browser used
• The used operating system
• Referrer URL
• The hostname of the accessing computer
• The time of the server inquiry
• The IP address

This data is not merged with other data sources.

This data is recorded on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

Cookie Consent

Our website uses Cookie Content technology to obtain your consent to the storage of certain cookies on your terminal device and to document this in a data protection-compliant manner.

When you enter our website, a connection is established to our servers to obtain your consent and other explanations regarding the use of cookies. A cookie is then set in your browser in order to be able to assign the consents you have given or to revoke them. 

The data collected in this way is stored until you request us to delete it, delete the cookie itself, or until the purpose for which the data is stored no longer applies. Mandatory legal storage obligations remain unaffected.

This technology is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6 Sect. 1 lit. c GDPR.

 

3.5 Plug-ins and Tools

Wistia Video

On our website we use the service Wistia to display videos. This service is offered by Wistia Inc. 17 Tudor Street, Cambridge, USA. Wistia uses so-called "cookies", text files which are stored on your computer and which enable an analysis of your use of the website. The information generated by the cookie about your use of this website is transferred to servers in the USA.

The processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.

 3.6  Registration on this website

You have the option to register on this website to be able to use additional website functions. We shall use the data you enter only for the purpose of using the respective offer or service you have registered for. The required information we request at the time of registration must be entered in full. Otherwise, we shall reject the registration.

To notify you of any important changes to the scope of our portfolio or in the event of technical modifications, we shall use the e-mail address provided during the registration process.

We shall process the data entered during the registration process on the basis of your consent (Art. 6(1)(a) GDPR).

The data recorded during the registration process shall be stored by us as long as you are registered on this website. Subsequently, such data shall be deleted. This shall be without prejudice to mandatory statutory retention obligations.

3.7 Newsletter data

If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail address as well as information that allow us to verify that you are the owner of the e-mail address provided, and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.

The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6(1)(a) GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose has ceased to apply. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6(1)(f) GDPR.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

 Online-based Audio and Video Conferences (Conference tools)

We employ the following conference tools:

Microsoft Teams

Data processing

We use online conference tools, among other things, for communication with our customers. The tools we use are listed in detail below. If you communicate with us by video or audio conference using the Internet, your personal data will be collected and processed by the provider of the respective conference tool and by us. The conferencing tools collect all information that you provide/access to use the tools (email address and/or your phone number). Furthermore, the conference tools process the duration of the conference, start and end (time) of participation in the conference, number of participants and other “context information” related to the communication process (metadata).

Furthermore, the provider of the tool processes all the technical data required for the processing of the online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.

Should content be exchanged, uploaded, or otherwise made available within the tool, it is also stored on the servers of the tool provider. Such content includes, but is not limited to, cloud recordings, chat/ instant messages, voicemail uploaded photos and videos, files, whiteboards, and other information shared while using the service.

Please note that we do not have complete influence on the data processing procedures of the tools used. Our possibilities are largely determined by the corporate policy of the respective provider. Further information on data processing by the conference tools can be found in the data protection declarations of the tools used, and which we have listed below this text.

Purpose and legal bases

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest in the meaning of Art. 6(1)(f) GDPR). Insofar as consent has been requested, the tools in question will be used on the basis of this consent; the consent may be revoked at any time with effect from that date.

Duration of storage

Data collected directly by us via the video and conference tools will be deleted from our systems immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal retention periods remain unaffected.

We have no influence on the duration of storage of your data that is stored by the operators of the conference tools for their own purposes. For details, please directly contact the operators of the conference tools.

Conference tools used

We employ the following conference tools:

Microsoft Teams

We use Microsoft Teams. The provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. For details on data processing, please refer to the Microsoft Teams privacy policy: https://privacy.microsoft.com/en-us/privacystatement.

Data processing

Microsoft Teams is managed by Royal Friesland Campina. They have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

4. MORE INFORMATION – How We Use Your Information

4.1 Sharing & Receiving Your Information With Others

Which other parties have access to your information?

DFE Pharma does not sell your information to others, but we make personal information available to partners that work with us to provide products and services, or that help us market to customers. Whether your information is provided to these partners depends on the nature of your interaction with us:

• Email marketing partners, call or e-mail
• Order fulfilment partners, to ship products to you and send you updates on the delivery
• Media agencies, to manage our website and apps and to display advertisements on the internet

Our partners only use your information under our instructions (with the exception of social media, which is out of our control). We take measures to ensure that your information is used only for the purposes described in this Privacy statement. Personal data will only be provided to supervisory bodies, fiscal authorities and/or investigating authorities if DFE Pharma is obliged to do so by law.

Matomo

This website uses the open-source web analysis service Matomo. Matomo uses technologies that make it possible to recognize the user across multiple pages with the aim of analyzing the user patterns (e.g. cookies or device fingerprinting). The information recorded by Matomo about the use of this website will be stored on our server. Prior to archiving, the IP address will first be anonymized.

Through Matomo, we are able to collect and analyze data on the use of our website-by-website visitors. This enables us to find out, for instance, when which page views occurred and from which region they came. In addition, we collect various log files (e.g. IP address, referrer, browser, and operating system used) and can measure whether our website visitors perform certain actions (e.g. clicks, purchases, etc.).

The use of this analysis tool is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the analysis of user patterns, in order to optimize the operator’s web offerings and advertising. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

IP anonymization

For analysis with Matomo we use IP anonymization. Your IP address is shortened before the analysis, so that it is no longer clearly assignable to you.

Hosting

We host Matomo with the following third-party provider:

[Name and address of the host]

Data processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

From which other parties do we receive your information?

DFE Pharma does not collect your personal information from others without you knowing about it first. If we receive information from others, we always ensure that we have your consent for receiving and using the information.

4.2 Storing Your Information

We use various systems and databases to store your personal information. Some are managed by DFE Pharma and others by our partners. Because we fully understand the importance of keeping your information secure, we have taken various technical and organisational measures to protect your information against loss or improper use. Our systems and applications are protected according to the applicable standards for information protection. Most personal information is stored within the European Union. If personal information is passed on to recipients in countries outside the European Union, we will take additional measures to protect your information.

4.3 Using Your Information to Improve Our Products and Services

DFE Pharma uses the information you provide to us to measure, analyse and improve our:

• Products, based on your feedback
• Websites and apps, based on your use

Your information will be anonymized before it is used. We are not interested in individual information but rather in trends and aggregated data.

4.4 Job Applications

We offer website visitors the opportunity to submit job applications to us (e.g. via e-mail, via postal services on by submitting the online job application form). Below, we will brief you on the scope, purpose and use of the personal data collected from you in conjunction with the application process. We assure you that the collection, processing and use of your data will occur in compliance with the applicable data privacy rights and all other statutory provisions and that your data will always be treated as strictly confidential. 

Scope and purpose of the collection of data

If you submit a job application to us, we will process any affiliated personal data (e.g. contact and communications data, application documents, notes taken during job interviews, etc.), if they are required to make a decision concerning the establishment or an employment relationship. The legal grounds for the aforementioned are § 26 New GDPR according to German Law (Negotiation of an Employment Relationship), Art. 6 Sect. 1 lit. b GDPR (General Contract Negotiations) and – provided you have given us your consent – Art. 6 Sect. 1 lit. a GDPR. You may revoke any consent given at any time. Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.

If your job application should result in your recruitment, the data you have submitted will be archived on the grounds of § 26 New GDPR and Art. 6 Sect. 1 lit. b GDPR for the purpose of implementing the employment relationship in our data processing system.

Data Archiving Period

If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6 para. 1 lit. f GDPR) for up to 6 months from the end of the application procedure (rejection or withdrawal of the application). Afterwards the data will be deleted, and the physical application documents will be destroyed. The storage serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the expiry of the 6-month period (e.g. due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.

Longer storage may also take place if you have given your agreement (Article 6 (1) (a) GDPR) or if statutory data retention requirements preclude the deletion.

Admission to the applicant pool

If we do not make you a job offer, you may be able to join our applicant pool. In case of admission, all documents and information from the application will be transferred to the applicant pool in order to contact you in case of suitable vacancies.

Admission to the applicant pool is based exclusively on your express agreement (Art. 6 para. 1 lit. a GDPR). The submission agreement is voluntary and has no relation to the ongoing application procedure. The affected person can revoke his agreement at any time. In this case, the data from the applicant pool will be irrevocably deleted, provided there are no legal reasons for storage.

The data from the applicant pool will be irrevocably deleted no later than two years after consent has been granted.

5. Your Privacy Rights

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. 

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6 SECT. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS.

If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time under the address disclosed in section “Information Required by Law” on this website if you have questions about this or any other data protection related issues.