AX for Pharma Privacy Policy

This Privacy Policy provides information concerning the protection of Personal Data provided by customers to AX for Pharma pursuant to their use of AX for Pharma’s web platform and related applications. This policy intends on describing the sources of Personal Data obtained by AX for Pharma, and the business purposes for which it is being used. We also recount for the customer, the latter’s rights under applicable law to receive disclosures concerning the use of their Personal Data and their rights to access, modify, erase and transfer their Personal Data.

AX for Pharma is a certified vendor under the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework, both established in 2016, and is committed to complying with the rules governing the use of Personal Data mandated both by the European Union’s General Data Protection Regulation and the California Consumer Privacy Act. For more information concerning the Privacy Shield Framework, see privacyshield.gov. For more information on the European Union’s General Data Protection Regulation, see ec.europa.eu/info/law/law-topic/data-protection_en. For more information concerning the California Consumer Privacy Act, see oag.ca.gov/privacy/ccpa.

The latest version of this document was published on March 25, 2020.

  • 1. Personal Data
    1. Personal Data received by AX for Pharma includes data entered into its web-platform, marketing data, data requested by AX for Pharma for recruitment opportunities and/or data used in tracking customer requirements and technologies (e.g. cookies).
    2. 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 via any media, such as mail, telephone, etc.
    3. Personal Data defined as Sensitive is a category of Personal Data required by local law (e.g. a European law) to be treated in accordance with specific rules and regulations, including acquiring authorization for usage from the person to whom the data belongs. Sensitive Personal Data is data that could be used to identify an individual and would include the names of customers, addresses, personal identification numbers (including IP addresses), information on ethnic origin, political and religious beliefs, union membership, personal health, criminal records, sexual orientation, and other physical data.
    4. Sensitive 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 conform with the requirements of applicable law. If a person voluntarily sends Sensitive Personal Data to AX for Pharma, AX for Pharma may use this data, subject to this Privacy Policy.
  • 2. Processing of Personal Data
    1. Security guides

      All of the steps that AX for Pharma will take shall be in furtherance of our organization’s effort to maintain and evolve operational procedures designed to meet local and international standards governing the protection of Personal Data, including the mandates of the General Data Protection Regulation and the California Consumer Privacy Act.

    2. How Data Security is conditioned by the environment

      It is important to understand that our website is not the only website on the world-wide-web. Personal Data can be freely held on network servers linking to our website without any external security procedure and therefore can be seen and utilized by people other than the original recipient.

      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 how those web hosts treat Personal Data. No personal data should be sent to these sites without first reviewing their data protection policies.

    3. Preservation

      As a company operating worldwide, AX for Pharma often receives Personal Data that can be preserved or transferred to others. In all such cases, the data protection policy followed will always remain the same, ensuring that the owner of Personal Data can count on the same level of protection and care regardless of where their personal data may be stored.

    4. Preservation length

      AX for Pharma will preserve your data for as long as it can be reasonably used for the benefit of AX for Pharma’s web platform. If the Personal Data is in a permanent account, the data will be preserved until reciprocal obligations have been satisfied.

    5. Liability

      AX for Pharma has responsibility for the processing of Personal Data, subsequently, transfers to third parties. AX for Pharma shall remain liable for the third-party treatment of Personal Data in violation of this Privacy Policy or applicable law, but only if AX for Pharma knew or should have known about such violations.

    6. Limitations

      AX for Pharma limits the collection of Personal Data to information that is relevant to its business purpose. AX for Pharma shall 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 customer.

  • 3. Sharing of Personal Data by AX for Pharma with Others

    AX for Pharma may transfer Personal Data, inter alia, to suppliers, affiliates, partners, and consultants in other countries. In doing so, we will ensure that the data transferred is adequately protected, as required by this Privacy Policy and applicable law. It is important to consider the following cases in which circumstances may require sharing data. These cases could involve:

    1. The participation in a joint promotion event, where specific information may be necessary;
    2. The need to use your Personal Data in relation to AX for Pharma’s security and the security of its customers, and third parties;
    3. The need to comply with a subpoena or other order of disclosure issued by a court, tribunal, or government agency that obliges us to disclose Personal Data.
  • 4. Your rights

    Among the rights, you shall have in connection with providing Personal Data to AX for Pharma are the following:

    1. The right to access your data to know what Personal Data is being collected;
    2. The right to correct errors in Personal Data that has been collected;
    3. The right to have your Personal Data erased;
    4. The right to transfer your Personal Data to a third party.

    You understand and acknowledge, however, that invoking certain of your rights may interrupt or render inoperative your use of certain portions of the AX for Pharma web platform and related applications.

    Should you choose to exercise the rights above or any other rights mandated by applicable law, you should contact, in writing, The Personal Data Department, AX for Pharma, 100 S. Ashley Drive, Suite 600 Tampa, FL 33602, USA.

    Customers, who believe their rights under the EU General Data Protection Regulation (GDPR) have been violated, may submit a complaint to the European Data Protection Authority for an adequate remedy, including compensation. For information on how to assert your rights under the GDPR see ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens/redress/what-should-i-do-if-i-think-my-personal-data-protection-rights-havent-been-respected_en.

    Under the California Consumer Privacy Act of 2018 (CCPA), which came into force on January 1, 2020, California residents are entitled, among other things, to request AX for Pharma to make the following disclosures and take the following actions:

    1. Disclose the categories and specific pieces of information AX for Pharma has collected (see Sections 1, 5, 7, 8, and 9, hereof);
    2. Disclose the categories of sources from which the personal information was collected (see Sections 5, 6,7, 8, and 9, hereof);
    3. Disclose the business and commercial purpose for collecting or selling Personal Data (see Sections 1, 2, 5, 7, 8, and 9, hereof);
    4. Disclose the categories of third parties with whom the business shares information (see Sections 6 and 7, hereof);
    5. The right to have Personal Data deleted, subject to certain exceptions;
    6. The right to prohibit the sale of Personal Data to third parties based on the customer’s election to opt out of the sale of such Personal Data.

    Customers who want to request disclosure of information mandated by the CCPA, in addition to the disclosures made herein, and/or to opt-out of the sharing of their Personal Data with third parties for marketing purposes should submit their requests, in writing, to The Personal Data Department., AX for Pharma, 100 S. Ashley Drive, Suite 600 Tampa, FL 33602, USA.

    In making your request, please include your account number and phone number in the body of your email or letter and describe the nature of your request in the subject line. It is important to note that concerning the customer’s right to Opt-Out of the sale to third parties of their Personal Data that opting out does not prohibit us from sending you important administrative disclosures for non-marketing purposes. We will comply with your request(s) as soon as reasonably practicable, but no later than 45 days from the receipt of any such request.

  • 5. Website

    AX for Pharma wants you to feel secure when visiting our website and is committed to maintaining your privacy when doing so. AX for Pharma collects information through its website in two ways: (1) directly (for example, when you provide information by way of subscribing to access our website, and/or to receive alerts, and notices); and (2) indirectly via the usage of Personal Data to deploy our applications. We may collect and process the following information: Information that you provide by filling in forms to register for our website, subscribing to services, notices, and alerts, registering for webinars and other events, and requesting research papers or further information on our products and services. 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 AX for Pharma website may also necessitate the use of your Personal Data. 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 for purposes of statistical analysis. Personal Data may also include information on 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 our separate policy on Cookies. We also 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.

    If you choose to provide 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 concerning 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 webinars and other AX for Pharma-sponsored events. You can choose not to receive e-mails from us at any time. We will not, however, share any e-mail addresses with any third party, or send unsolicited e-mails to any of the addresses we collect, except in very limited circumstances as outlined in this policy.

  • 6. International Transfer of Information

    AX for Pharma is a global organization. It is possible that information collected on this Site may be transferred among the AX for Pharma 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 Personal Data.

    By using our Site, submitting information through the Site, or submitting information to AX for Pharma through other means, you voluntarily consent to such international transfer of Personal Data and the storage of such information.

  • 7. Marketing

    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 customers and other companies with whom 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 customer or other company.

    We send e-mails for marketing purposes to individuals affiliated with customers 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 to you when clicked. When you click a link in a marketing e-mail from AX for Pharma, a cookie will be introduced that will, among other things, log what pages of the AX for Pharma website 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 AX for Pharma may include additional information concerning the protection of Personal Data, as may be required by applicable law.

    We may aggregate data from publicly available sources, and from responses to e-mails, website, and personal interactions with you. Our aim in collecting and aggregating this Personal Data is to better understand your needs and the needs of your company, to assess the suitability of our service offerings for your needs, and to be able to enhance the efficiencies and responsiveness of our services.

  • 8. Recruiting

    If you use AX for Pharma online career resources, we collect personal data that you submit to the website and use it for recruiting-related purposes. We may also use cookies and other tracking technology and the same technologies we use for marketing to provide individuals with a personalized online experience, to send relevant information about careers and opportunities at AX for Pharma, and to analyze the effectiveness of our recruitment efforts and resources. Information about how your data will be used by AX for Pharma during the recruitment process will be provided at the beginning of that process.

  • 9. Security Processes

    AX for Pharma has in place technological and operational security processes designed to protect Personal Data from loss, misuse, alteration, and destruction. Only authorized employees and contractors will have access to your Personal Data, and then, only on a need to know basis. Each employee or contractor having access to your Personal Data is obligated to maintain its confidentiality. Notwithstanding AX for Pharma’s efforts to protect Personal Data, you acknowledge and understand that AX for Pharma cannot guarantee that your Personal Data may not become subject to hacking and consequent disclosure to unauthorized persons or entities. In the event of the successful hacking of Personal Data held on our servers, remedial measures shall be taken to mitigate any damage to our customers under prevailing law and industry custom and practice, including that customers shall be promptly notified concerning any data breach.

  • 10. Links to Other Web Sites

    This site may contain links to other sites. AX for Pharma is not responsible for the privacy practices or the content of any non-AX for Pharma web sites to which we link from this Site.

  • 11. Compliance with Law

    AX for Pharma is committed to protecting the Personal Data you share with us. However, there are circumstances where AX for Pharma may be compelled to disclose 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 need to disclose Personal Data to our affected business partners, consultants, professional service providers, including attorneys.

  • 12. Questions or Complaints

    If this document does not provide the answers you are looking for, or if there are any doubts regarding how we intend on using your Personal Data, please contact us by email at the following address privacy@axforpharma.com.

Contact Us

North America

AX for Pharma North America LLC.
100 S. Ashley Drive, Suite 600
Tampa, FL 33602
United States

Europe

AX for Pharma Europe
Centro Direzionale Milano Due
Palazzo Bernini, 701-704
20090 Segrate (Milan)
Italy