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A. Menarini Industrie Farmaceutiche Riunite S.r.l. (“Company”) hereby informs you that the processing of your personal data, carried out via the website (“Website”) or collected through this contact form (“Form”), is conducted in accordance with applicable privacy regulations (Regulation (EU) 2016/679 – hereinafter referred to as the “Regulation”) and the Website’s Privacy Policy.

1. Data Controller and DPO

The Data Controller is A. Menarini Industrie Farmaceutiche Riunite S.r.l., with registered office at Via dei Sette Santi 1/3, Florence (“Data Controller”).
The Data Protection Officer (“DPO”) can be contacted at the following address: dpo@menarini.com

2. What data we process

With your consent, we process the personal data you provide when you interact with the newsletter subscription form. This data includes, in particular, your first name, last name, contact information, country, age, as well as any additional data that the Data Controller may collect, including from third parties, in the course of its business (“Data”).
To allow us to process the requests you send us via the contact form, you must consent to the processing of the data you enter and provide at least the information marked with an asterisk (*). If the required data or consent is missing, we will not be able to proceed. Conversely, consent and the information requested in fields not marked with an asterisk are optional: if you choose not to provide them, there will be no consequences.
In any case, the Data Controller may process your Data, even without your prior consent, to comply with legal obligations, regulations, and EU legislation; to exercise rights in court; to pursue its legitimate interests; and for all cases provided for in Articles 6 and 9 of the Regulation, where applicable.
Processing is carried out using both electronic and paper-based means, applying the security measures required by current legislation.

3. Why we process your data and how

Your data is processed for the following purposes:

*to manage your request to subscribe to the newsletter; the legal basis for processing your personal data for this purpose is your consent (Article 6(1)(a) of the Regulation). Please note that the newsletters you receive contain a “pixel tag,” through which the Company collects certain information, e.g., whether and when you opened and/or deleted the email, which links in the newsletter you clicked, your email client, whether the email was opened from more than one IP address, as well as certain anonymous and aggregated information regarding users’ geographic locations, etc. The Company processes this information to verify the effectiveness of its informational campaigns, pursuant to Article 6.1.(f) of the Regulation. Many service providers and email clients allow you to set a specific function that prevents such tracking—please check the relevant settings if you do not wish the Company to process the aforementioned information.

By checking the appropriate box, you consent to the processing for the aforementioned purpose.

Your data may, however, be processed—even without your consent—to comply with legal obligations, regulations, and EU legislation (Article 6.1.(c) of the Regulation), to compile statistics on the use of the Website and ensure its functionality (Article 6.1. (f) of the Regulation), to implement the Menarini Group Code of Conduct, and to defend its rights in court (Articles 6.1.(f) and 9.2.(f) of the Regulation).

Personal data is entered into the company’s information system in full compliance with applicable privacy regulations, including security and confidentiality requirements, and in accordance with the principles of fairness, lawfulness, and transparency in processing. The data will be retained for the period strictly necessary to achieve the purposes for which it was collected; in any case, the criterion used to determine this period is based on compliance with the timeframes permitted by applicable laws and the principles of data minimization, storage limitation, and rational archive management.

All user data is also processed using both paper-based and automated tools, all of which are suitable for ensuring security and confidentiality.

4. Who Has Access to the Data

The Data is accessible to the Data Controller’s personnel authorized to process it, and in particular to administrative staff, IT technicians, personnel from the Medical and Marketing Department, medical representatives, and other individuals who need to process the Data in the performance of their duties. The Data may be disclosed, including to countries outside the EU (“Third Countries”), to: (i) institutions, authorities, and public bodies for their institutional purposes; (ii) professionals, independent contractors, including those in partnerships; third parties and suppliers used by the Data Controller to provide commercial, professional, and technical services necessary for the management of the Website and its features (e.g., IT and cloud computing service providers), for the purposes specified above, and for the services you have requested; (iii) third parties in the event of mergers, acquisitions, the sale of a business or business unit, audits, or other extraordinary transactions; (iv) the Company’s Supervisory Board, domiciled at the Data Controller’s premises, for the pursuit of its supervisory activities and the enforcement of the Menarini Group Code of Conduct.
The Data may be disclosed, including to countries outside the EU (“Third Countries”), to other companies within the Menarini Group for the same purposes and/or for administrative and accounting purposes pursuant to Article 6.1.(f) and Recital 48 of the Regulation.
Such parties will receive only the Data necessary for their respective functions and will undertake to use it solely for the purposes indicated above and to process it in compliance with applicable privacy regulations. The Data may also be disclosed to legitimate recipients as required by law or regulation. Except as provided above, the Data is not shared with third parties—whether natural or legal persons—who do not perform any commercial, professional, or technical functions for the Data Controller, and will not be disclosed. The parties receiving the Data process it as Data Controllers, Data Processors, or authorized processors, as applicable, for the purposes indicated above and in compliance with applicable privacy regulations.
With regard to any transfer of Data to Third Countries, including countries that may not guarantee the same level of protection provided by the applicable Privacy Regulations, the Data Controller hereby states that processing will in any case take place in accordance with one of the methods permitted by the Regulation, such as your consent, the adoption of Standard Contractual Clauses approved by the European Commission, the selection of entities participating in international programs for the free flow of data, (e.g., EU-U.S. Privacy Shield) or operating in countries deemed safe by the European Commission.

5. Your Rights

By contacting the Data Controller at the contact details provided above, you may, at any time, exercise the rights set forth in Articles 15–22 of the Regulation, such as accessing the updated list of parties who may access your Data, obtaining confirmation of the existence or otherwise of personal data concerning you, verifying its content, origin, accuracy, and location (including with respect to any third countries), requesting a copy, requesting its rectification, and, in the cases provided for by applicable law, requesting restriction of processing, erasure, or objection to direct contact activities (including limited to certain means of communication). Similarly, you may always report observations regarding specific uses of data in connection with particular personal situations deemed incorrect or not justified by the existing relationship to the DPO or file a complaint with the Data Protection Authority. At any time, you may revoke your previously given consent, without this affecting the lawfulness of the processing carried out prior to the revocation of consent.