The latest version of this document was issued on December 17, 2018.
- Personal Data.
a. Personal Data received by AX for Pharma includes data entered in the website, marketing data, data requested by AX for Pharma for recruitment opportunities and/or data used in tracking technologies (e.g. cookies).
b. Personal Data collected by AX for Pharma includes the data of employees, individual contractors, professional partners and suppliers, users of the website or users requesting information on any media, such as mail, telephone, etc.
c. Personal Data defined as Sensitive is a category of personal data required by local law (e.g. a European law) to be treated with specific rules and regulations, including acquiring authorization for usage from the Person to whom the data belongs. Examples of Sensitive data include personal identification numbers, ethnic origin, political and religious beliefs, Union membership, personal health, criminal records, sexual orientation and other physical data.
d. Personal Data is generally not requested by AX for Pharma. If deemed necessary for the conduct of the business, the request for such data and its protection will be done according to local country laws. If a person willingly sends sensitive personal data not requested by AX for Pharma, AX for Pharma may use this data where permitted by local law.
Processing of Personal Data
a. Security guides
All of the steps indicated above are to ensure that our organization maintains and evolves operational procedures that warrant the appropriate level of security of Personal Data. Our procedures reflect the standard indicated in European laws regarding Privacy of Data and are in line with the requirements of the European Economic Area and Switzerland.
b. How Data Security is conditioned by the environment
It is important to understand that our website is not alone on the web. Internet Personal Data can be freely present on networks linking to our website without any external security procedure and therefore can be seen and utilized by people other than the original target.
Our site may contain links both to and from websites of partners, customers, affiliates, etc. These sites may have different privacy policies and we do not accept any responsibility for their treatment of data. No personal data should be sent to these sites without checking their policies.
As a Company operating worldwide, the Personal Data AX for Pharma collects can be preserved or transferred to the entire world. In all such cases, the Data Processing policy followed will always remain the same, ensuring that the owner of the Personal Data can count on the same level of protection and care regardless of location.
d. Preservation length
AX for Pharma will preserve your data only for the time necessary. If the Personal Data is in a permanent account, the data will be preserved until necessary to satisfy the reciprocal obligations.
In the context of an onward transfer, AX for Pharma has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. AX for Pharma shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles unless the organization proves that it is not responsible for the event giving rise to the damage.
AX for Pharma limits the collection of Personal Data covered by this Privacy Shield Policy to information that is relevant for the purposes of processing. AX for Pharma does not process such Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual.
Sharing of Personal Data by AX for Pharma with Others
AX for Pharma could potentially transfer Personal Data to suppliers and consultants in other countries. In doing so, we will ensure that the data transferred is adequately protected, as required by law. It is important to consider the following cases in which circumstances may require sharing data. These could be:
a. The participation in a joint promotion event, where specific information may be necessary
b. The need to use your Personal Data pertaining to the security of AX for Pharma, its customers and third parties.
c. Law compliance requirements that oblige the disclosure of the Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
It is your right to know if AX for Pharma keeps your Personal Data and, if so, request access to such information and mandate that it be corrected, amended or deleted if Personal Data is inaccurate or has been processed in violation of the Privacy Shield Principles. Such requests should be sent in writing to the Personal Data Dpt., AX for Pharma 100 S. Ashley Drive, Suite 600
Tampa, FL 33602, USA.
Below is the specific procedure to follow if your Data was originally collected in Europe (Economic European Area and in Switzerland) and has been transferred to any entity of AX for Pharma outside of Europe. Based on the European law you have the following rights:
a. Make a complaint to obtain an adequate remedy, and eventually receive a compensation from the European entity who originally received your Personal Data
c. Receive a copy of the Privacy Data Protection Policy of AX for Pharma
An individual has the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. For further information regarding this matter, https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
AXPNA want you to feel secure when visiting our website and are committed to maintaining your privacy when doing so. AXPNA collects information at its websites in two ways: (1) directly (for example, when you provide information to sign up for a newsletter or register to comment on a forum website); and (2) indirectly (for example, through our website’s technology). We may collect and process the following information: Information that you provide by filling in forms on our website. This includes registering to use the website, subscribing to services, newsletters and alerts, registering for a conference or requesting a white paper or further information. Pages that collect this type of information may provide further information as to why your data is needed and how it will be used. It is completely up to you whether you want to provide it. If you contact us, we may keep a record of that correspondence. We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them. Any postings, comments or other content that you upload or post to an AXPNA website. Our website collects information about your computer, including (where available) your IP address, operating system and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics. Details of your visits to our website, the pages you view and resources you access or download, including but not limited to, traffic data, location data, weblogs and other communication data. Please see the Cookies section below for more information. All this information is managed as personal data, therefore the collection, the storage and the usage will be done in accordance with the General Data Protection Regulation. We use personal data to provide you with information you request, process online job applications, and for other purposes which we would describe to you at the point where it is collected, or which will be obvious to you.
Fulfilling your requests for white papers, articles, newsletters or other content. For surveys or research questionnaires. To personalize your experience on our website. To contact you for marketing purposes where you have agreed to this. We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and make it more effective. We use IP addresses to help diagnose problems, to administer our website, and to gather demographic information. Please see the Cookies section below for more information.
If you choose to give us your e-mail address, we will communicate with you via e-mail. We may collect the e-mail addresses at the point of subscription, of users who wish to receive e-mail notification of publications and press releases in identified subject areas of interest, and of those who send us e-mail messages or express interest regarding our services or employment opportunities, or register for conferences and other AXPNA-sponsored events. You can choose not to receive any more e-mail at any time. We will not, however, share any e-mail addresses with any third party or send unsolicited e-mail to any of the addresses we collect, except in very limited circumstances as set forth in this policy.
International Transfer of Information
AXPNA is a global organization. It is possible that information collected on this Site may be transferred among the AXPNA offices or personnel, or to third parties located throughout the world, including offices located outside the European Economic Area, and this Site may be viewed and hosted anywhere in the world, including countries that may not have laws regulating the use and transfer of personally-identifiable data. AXPNA complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union member countries. AXPNA has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, please visit http://www.export.gov/safeharbor/.
By using the Site, submitting information through the Site, or submitting information to AXPNA through other means, you voluntarily consent to such international transfer and hosting of such information.
Tracking technologies (e.g. cookies)
AXPNA use tracking technologies (e.g. cookies) to deliver personalized content, to save you having to re-enter your password repeatedly and to tailor our information offerings to how you and others use the site. Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device.
Cookies do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help to ensure that the advertisements and other content you see online are more relevant to you and your interests. They can be set by the website that you are visiting (known as first party cookies) or by another entity such as an advertising network (known as third party cookies).
By using our website, you agree that we can place cookies and other similar technologies on your device. If you want to remove existing cookies from your device, you can do this using your browser options. If you want to block future cookies being placed on your device, you can change your browser settings to do this.
Please bear in mind that deleting and blocking cookies will have an impact on your user experience as parts of the website may no longer work. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon as you visit our website or click a link in a targeted email we have sent you, even if you have previously deleted our cookies.
You cannot remove or block web beacons or personalized URLs, as they form part of the content of web pages and emails rather than placing information on your device. But, as they work in conjunction with cookies, turning off cookies will also prevent any web beacons from tracking your user activity on our site. The web beacon will still account for an anonymous visit, but your unique information will not be recorded.
The following describes our use of personal data for marketing purposes.
The personal data we collect and use for marketing purposes relates to individual employees of our clients and other companies with which we have an existing business relationship. We may also obtain contact information from public sources, including content made public at social media websites, to make initial contact with a relevant individual at a client or other company.
We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from AXPNA, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site. Targeted e-mails from AXPNA may include additional data privacy information, as required by applicable laws.
We may combine data from publicly available sources, and from our e-mail, website, and personal interactions with you. We combine this data to better understand your needs and the needs of your company, to assess the suitability of our service offerings for your needs, and to perform the other activities described throughout this privacy statement.
Personal data collected will be managed in accordance with international and national laws.
AXPNA has in place technological and operational security processes designed to protect personally identifiable information from loss, misuse, alteration or destruction. Only authorized employees and contractors will have access to any data provided by you, and that access is limited by need. Each employee or contractor having access to any personally-identifiable information is obligated to maintain its confidentiality. Although we take steps that are generally accepted as an industry standard to protect your personally-identifiable information, AXPNA cannot guarantee that your personally-identifiable information will not become accessible to unauthorized persons.
Links to Other Web Sites
This site may contain links to other sites. AXPNA is not responsible for the privacy practices or the content of any non-AXPNA web sites to which we link from this Site.
Compliance with Law
AXPNA is committed to protecting the personal data you share with us. AXPNA may be compelled to surrender personal user or customer information to legal authorities without express user consent if presented with a court subpoena or similar legal or administrative order, or as required or permitted by the laws, rules and regulations of any nation, state or other applicable jurisdiction. Also, in the event of a violation of the terms and conditions of use of this Site or a violation of any restrictions on the use of materials provided in or through this Site, we may disclose personal user information to our affected business partners or legal authorities.
Questions or Complaints
If this document does not provide the answers you are looking for or if there are any doubts regarding the usage of your Personal Data by AX for Pharma, please contact us by email to the following address firstname.lastname@example.org.
In compliance with the Privacy Shield Principles, AX for Pharma commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact AX for Pharma at: email@example.com.
AX for Pharma has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) regarding unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.
AX for Pharma is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).