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Conditions for the processing of personal data

Introduction

Tuscan Biochemical Drug (Farto S.r.l) Cod. Fis. 06569640482 – Viale Alessandro Guidoni, 97 – 50127 – Florence (FI), takes user privacy very seriously and is committed to respecting it. This privacy policy (“Privacy Policy”) therefore describes the processing of personal data carried out by Farto S.r.l through its website (www.fartosrl.com) and the related commitments undertaken in this sense by the company. Farto srl can process the user’s personal data when they visit the Site and use the services and features on the Site. The Privacy Policy supplements and / or constitutes information to the interested parties pursuant to art. 13 of Legislative Decree 30 June 2003, n. 196 and subsequent amendments and additions (CODE RELATING TO PROTECTION OF PERSONAL DATA ref. Http://www.garanteprivacy.it/ (from now on “Privacy Code”).

Data controller

The data controller is Farto Srl, with headquarters in Viale Alessandro Guidoni, 97 – 50127 – Florence (FI), telephone +39 055 411 267, toll-free number 800 76 76 33

Types of data processed

The visit and consultation of the Site do not generally involve collection and processing of personal data of the user except for navigation data and cookies as specified below. In addition to the so-called “navigation data” (see below), personal data voluntarily provided by the user may be processed when the latter interacts with the functionalities of the Website or requests to use the services offered on the Site. In compliance with the Privacy Code, Farto Srl may also collect the user’s personal data from third parties in the course of their business.

In the sections of the Site in which the personal data of the user are collected, a specific disclosure is normally published pursuant to art. 13 of the Privacy Code. Where required by the Privacy Code, the consent of the user will be required before proceeding to the processing of his personal data. If the user provides personal data of third parties, he must ensure that the communication of data to Farto S.r.l. and the subsequent processing for the purposes specified in the applicable privacy policy is in compliance with the Privacy Code and applicable legislation, so for example the user can provide personal data of third parties only after having duly informed and having received consent to treatment.

Navigation data and cookies

The processing of personal data of users who visit the Site is limited to browsing data, ie those for which transmission to the Site is necessary for the operation of the computer systems responsible for managing the Site and Internet communication protocols. This category includes, for example, the IP addresses or the domain of the computer used to visit the Site and other parameters relating to the operating system used by the user to connect to the Site. Farto S.r.l. collects these and other data (such as, for example, the number of visits and the time spent on the Site) only for statistical purposes and anonymously in order to monitor the operation of the Site and improve its functionality. This is information that is not collected to be associated with other user information and identify the latter; however such information by its very nature can allow the identification of users through processing and association with data held by third parties. Navigation data is immediately deleted after being processed anonymously but may be used by Farto S.r.l. to ascertain and identify the perpetrators of any computer crimes committed against the Site or through the Site. Save this eventuality, the navigation data described above are only temporarily stored in compliance with the applicable legislation.

Cookies are small files stored on the user’s computer hard disk. The Site uses cookies c.d. “Session” and “persistent”.

Session cookies are temporary strings of information that are used to facilitate navigation on the Site, for purposes of internal security and system administration. These cookies do not contain information about the user, are only temporarily stored and are deleted when the user closes the browser.

Persistent cookies have a variable duration (from one hour to one year). Farto srl uses this type of cookie for the sole purpose of storing the language selected by the user and sending statistical information to the Google Analytics system, through which Farto S.r.l. can carry out statistical analysis of accesses / visits to the Site. The cookies used are exclusively for statistical purposes and collect information in aggregate form. Through a pair of cookies, one of which is persistent and the other one of session (with expiration at browser closure), Google Analytics also saves a register with the times of the beginning of the visit to the Site and exit from the same.

The Site may contain links to other sites (c.d. third party sites). Farto srl does not make any access or control over cookies, web beacons and other user tracking technologies that could be used by third party sites that the user can access from the Site; Farto srl does not carry out any control on contents and materials published by or obtained through third party sites, nor on the relative methods of processing of the user’s personal data, and expressly disclaims any relative responsibility for such eventualities. The user is required to check the privacy policies of third-party sites accessed through the Site and to inform himself about the conditions applicable to the processing of his personal data. This Privacy Policy applies only to the Site as defined above.

Most browsers automatically accept cookies, but the user can normally change the browser settings to disable this function. The “Help” section of the toolbar in most browsers shows how to avoid receiving cookies, web beacons and other user tracking technologies, how to get notification from the browser about the activation of these technologies or how to disable them completely. Disabling cookies may limit the ability to use the Site and prevent the user from fully benefiting from the features and services on the Site.

Place of storage of personal data

Personal data is stored and processed through IT systems owned by Farto S.r.l. and managed by Farto S.r.l. or from third party technical service providers; for more details, please refer to the “Accessibility of personal data” section below. The data is processed exclusively by specifically authorized personnel, including the personnel responsible for carrying out extraordinary maintenance operations.

Purposes and methods of processing

Farto srl can process common and sensitive personal data of the user for the following purposes: use by users of services and features present on the Site; management of requests and reports by its users, including pharmacovigilance; management of requests for information, promotional material and communications, including commercial ones; sending newsletters; management of applications received through the Website, etc.

Personal data are processed both in paper and electronic form and entered into the company information system in full compliance with the Privacy Code, including security and confidentiality profiles and inspired by the principles of correctness and lawfulness of treatment. In accordance with art. 11 of the Privacy Code, the data is kept and stored for a period of time not exceeding that necessary to achieve the specific purposes pursued from time to time.

Security and quality of personal data

Farto srl undertakes to protect the security of the user’s personal data and complies with the provisions on security provided for by the applicable legislation in order to avoid loss of data, illegitimate or illegal use of data and unauthorized access to the same, with particular but not exclusive reference to Annex B of the Privacy Code (Technical Regulations regarding minimum security measures). Furthermore, information systems and computer programs are configured in such a way as to minimize the use of personal and identification data; these data are processed only to achieve the specific purposes pursued from time to time. Farto srl uses multiple advanced security technologies and procedures to promote the protection of users’ personal data; for example, personal data is stored on secure servers located in places with protected and controlled access. The user can help Farto S.r.l. to update and maintain their personal data by communicating any changes to their address, their qualifications, contact information, etc.

Scope of accessibility of personal data

The user’s personal data is accessible within Farto S.r.l. to the staff in charge of processing who, in relation to their duties, needs to treat them to fulfill the user’s requests regarding the use of the services and features on the Site and in any case with regard to the purposes described above. The data may also be communicated to the companies that collaborate with Farto S.r.l. for the same purposes and / or for administrative and accounting purposes pursuant to art. 34 paragraph 1-ter of the Privacy Code and to third parties to whom Farto S.r.l. addresses for the execution of commercial, professional and technical services functional to the aforementioned purposes. Without prejudice to the above, your personal data are not disclosed to third parties, natural or legal persons, nor are they disclosed in any way.

Nature of data provision

The provision of some personal data by the user is required to allow Farto S.r.l. to manage communications, applications received through the Site, or requests received from the user (eg: requests for information, materials and communications) or to contact the user himself to comply with his request.

This type of data is marked with the asterisk symbol [*] and in this case the conferment is obligatory to allow Farto S.r.l. to comply with the request that, in default, cannot be processed. On the contrary, the collection of other data is optional: failure to provide it will not entail any consequence for the user. The provision of personal data by the user for sending the Farto S.r.l. newsletter it is optional and in case of refusal there will be no consequences for the user, except of course the impossibility to receive the newsletter.

User rights

The user can exercise the rights recognized by the art. 7 of the Privacy Code, including the right to obtain confirmation of the existence or not of personal data concerning him, verify the content, origin and accuracy, request integration, updating, rectification, cancellation , the transformation into anonymous form, the blocking of data processed in violation of the law, the opposition to the processing of data for legitimate reasons.

For any request concerning the processing of personal data by Farto Srl , to exercise the rights recognized by the Privacy Code, as well as to know the updated list of the subjects to which the data are accessible, the user can contact the Data Controller at the addresses indicated above.

Summary

INFORMATIVE NOTE FOR THE TREATMENT OF PERSONAL DATA OF THE LADIES PHARMACISTS EX D.LGS. June 30, 2003 N. 196 CONSOLIDATED (“PRIVACY CODE”)

Egr. Doctor,

we would like to inform you that in order to comply with the formalities required by Legislative Decree 219/2006 on the advertising of medicines and in particular on that concerning the communication to AIFA of the number of Pharmacists visited annually as part of the scientific information on the drug carried out by our scientific informants, your personal data (name and surname ) are the subject of specific treatment by our Company.

The Data Controller and Data Processor is Farto Srl .The processing will take place by computer and manual means according to the logics and procedures functional to the purposes specified above and in compliance with the Privacy Code, including the security and confidentiality profiles of the data.

Your data will be available to the Manager, as well as to the network of scientific informants of the drug and internal employees of the Company, in charge of processing. Furthermore, your data may be shared between the companies that collaborate with Farto Srl where engaged in the execution of activities connected with the above-mentioned obligations, your data will not be accessible or shared with anyone other than those indicated above and will not be disclosed in any way.

The complete and updated list of the subjects who have access to Your data is available, upon request, from the Data Processor. You can exercise your rights under the art. 7 of the Privacy Code, for example request confirmation of the existence or not of data concerning you, verify its content, origin, accuracy, request its integration, update, rectification, cancellation, transformation into anonymous form, block for violation of the law, oppose the processing for legitimate reasons by contacting the Manager of the Treatment at the Company’s addresses indicated above, or at the email address info at fartosrl dot com (please replace at with “@” and dot with “.”)

Summary

MEDICAL CLASS PRIVACY INFORMATION

Dear Doctor,

Chiar.mo Prof,

as required by the Privacy Code (art. 13 Legislative Decree 196/03), we inform you that the Owner and Manager of the Processing of your data is Farto S.r.l. with headquarters in Viale Alessandro Guidoni, 97 – 50127 – Florence (FI).

1. Purpose of the processing

We process your personal data, delivered today or already collected during previous contacts, for the following purposes:

a) scientific information on drugs and related activities, such as, for example, the presentation of medicines, the collection of requests of samples, sending of promotional material on medicines, activities carried out in compliance with Legislative Decree n. 219/2006,

b) classification of your data within the company electronic archive. In particular, the Data Controller may perform profiling in order to improve the efficiency of scientific information.

2. Data processed

The personal data that will be processed for the above purposes

(1) Professional title;

(2) Name;

(3) Surname;

(4) Date and place of birth;

(5) Year of graduation;

(6) Sex;

(7) Tax Code;

(8) Visiting and correspondence addresses (via, civic, city, post code, provinces);

(9) Visiting hours;

(10) Tel. Of the workplace;

(11) Mobile phone number;

(12) Work sector (eg basic general practitioner, specialist practitioner, doctor practicing in hospital or similar facilities, medical guard, tourist guard or rescue medicine 118, etc.);

(13) Any specializations;

(14) Average number of borrowers;

(15) Position / position held within the hospital or similar facility;

(16) of free choice or for territorial specialization with the NHS for general medicine or pediatrics;

(17) Participation in association activities pursuant to Law 8 November 2012 n. 189 on the reorganization of the territorial assistance. The scientific and informational activity of this information is the one that is provided for you. . All the data you have acquired in order to carry out classification activities: in this case your consent is optional, provided that your refusal will allow you to provide an information service that specifically meets your needs.

3. Processing methods

Your personal data will be processed in full compliance with the Privacy Code, including security and confidentiality profiles and inspired by the principles of correctness and lawfulness of processing.

4. Scope of knowledge and communication of data

Your data may be known to the Manager as well as to the network of scientific informants of the drug and to the designated internal treatment personnel.

Furthermore, in relation to the obligations and purposes indicated above, your data may be disclosed to third party companies, such as suppliers, sub-suppliers, professional offices and companies that carry out tax or administrative activities on behalf of the Data Controller. In the event that your personal data is communicated to such third parties, the same protections already adopted by the Data Controller will be guaranteed.

The complete and updated list of data processors and other subjects to whom your data may be communicated is available upon request from the Data Processor indicated above.

5. Data retention times

In accordance with the art. 11 of the Privacy Code, the data relating to you will be kept and stored for a period of time not exceeding that necessary to achieve the purposes for which they are processed.

6. Privacy rights of the interested party

We inform you that at any time you can exercise your privacy rights as set forth in art. 7 of the Privacy Code; You can then access your data, check its accuracy, request its integration, update, rectify, and oppose the processing for legitimate reasons, etc. by contacting the Data Processor at Farto Srl  , based in Viale Alessandro Guidoni, 97 – 50127 – Florence (FI), at the following addresses:

phone +39 055 411 267, email info at fartosrl dot com (please replace at with “@” and dot with “.”).