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HORUS PHARMA is committed to protecting the personal information and privacy of visitors to the Website and of anyone using its Services in general.

The purpose of this Privacy and Cookie Policy is to inform you:

  • The types of personal data we collect about you
  • How your personal data is processed by HORUS PHARMA and its potential partners and subcontractors
  • The terms and conditions governing the use of your personal data and your rights in this regard, in compliance with applicable European and French legislation
  • All processing of your personal data is carried out in compliance with applicable regulations, including Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “GDPR”), and any applicable national data protection laws.

    1. DEFINITIONS

  • Personal data – any information relating to an identified natural person or a natural person who can be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to that person.
  • File – any structured and stable set of personal data accessible according to specific criteria.
  • Data subject – a natural person to whom the data being processed relates;
  • Data controller – the entity that collects and processes personal data;
  • Data processing – any operation or set of operations performed on such data, regardless of the method used, including collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, as well as blocking, erasure, or destruction;
  • Recipient – any person authorized to receive the data other than the Data Controller, the Processor, and those persons who, by virtue of their duties, are responsible for processing the data;
  • Authorized third parties – authorities legally empowered, within the framework of a specific mission or the exercise of a right to disclosure, to request that the Data Controller provide them with personal data;

    2. IDENTITY OF THE DATA CONTROLLER

HORUS PHARMA SAS, 22 Allée Camille Muffat, INEDI 5, 06200 Nice, France

3. PROCESSING OF PERSONAL DATA

In the course of its business operations, HORUS PHARMA collects data about you. This data is processed in accordance with the purposes specified at the time of collection, with certain information being mandatory and other information optional, as indicated in the collection forms.  

Furthermore, HORUS PHARMA may collect personal data for other purposes, taking care to obtain the prior consent of the individuals concerned.

3.1. PROCESSING IN CONNECTION WITH THE WEBSITE

The processing operations implemented on our website https://www.horus-pharma.com/fr/ are intended to enable:

  • Contacting us via the form provided
  • The compilation of statistics regarding website traffic
  • The management of the ability to share content on social media

Data collection is based on your consent, which you provide by accepting the use of cookies, by checking the relevant box on the data collection form, or by writing to us directly.

Processing may be based on the legitimate interest of HORUS PHARMA, particularly for the proper functioning of the website.

HORUS PHARMA may collect the following data from you:

Contact form

Identification data, professional data, and contact data: last name, first name, email address, phone number, subject of messages

Statistics; Cookies and other trackers

Connection data: pages viewed by the user, date and time of visit, geographic location, source of the connection (social media, search engine, partner site, directory).

3.2. PROCESSING FOR MARKETING PURPOSES

The processing carried out for marketing purposes is intended to enable:

  • Contract management (e.g., management of orders, delivery, service provision or supply of goods, invoices, and payments);
  • The management of loyalty programs;
  • Maintenance of general ledger accounts and any subsidiary ledgers associated with them;
  • The preparation of financial statistics;
  • Conducting satisfaction surveys and customer studies, including polls, product tests, and sales statistics compiled by the relevant organization;
  • Managing complaints, after-sales service, and warranties;
  • Conducting sales prospecting and marketing activities (sending advertising messages, contests, referrals, promotions, surveys);

The processing is based on the legitimate interest of HORUS PHARMA, particularly for the development of the network with healthcare professionals.

HORUS PHARMA may collect the following data from you:

  • Identification data: last name, first name, phone number, fax number, email address, mailing address.
  • Professional data: title or position, department, specialty.

You may opt out of receiving communications from us at any time by clicking the link provided for this purpose in our emails.

 3.3. PROCESSING WITHIN THE FRAMEWORK OF CONTRACTUAL RELATIONSHIPS

The processing carried out within the framework of contractual relationships is intended to enable:

  • The management of contracts, orders, deliveries, invoices, accounting, and customer relationship management.
  • The compilation of sales statistics.
  • The management of requests for access, rectification, and objection.
  • The management of unpaid invoices and disputes.
  • The management of user feedback on products, services, or content.

Data collection is based on the performance of the contract signed with HORUS PHARMA.

Processing may be based on HORUS PHARMA’s legitimate interest, as the customer database is considered representative of the customer base, defined as an essential element of the business assets under the law of March 17, 1909.

HORUS PHARMA may collect the following data from you:

  • Identification data: last name, first name, title, phone number, fax number, mailing address, email address, internal customer code.
  • Professional data: department, specialty, shipping address, product reviews, customer comments, correspondence with customer service, date of participation in promotional campaigns, requests for documentation, samples provided, purchase history, amount, reason for and responsibility regarding the complaint, nature of promotional items offered, origin of the order, origin of the sale, frequency, product purchased, quantity, product returns.
  • Financial data: credit balance, outstanding payments (without excluding the individual), payment terms, check number, receipts, discounts granted.
  • IT data: website address, date, time, page visited, visitor’s computer protocol.

3.4. PROCESSING IN THE CONTEXT OF MEDICAL INFORMATION

The processing carried out in the context of medical information is intended to enable:

  • The management of medical information (responses regarding products received via contact forms and phone calls).

Data collection is based on compliance with legal obligations to which HORUS PHARMA is subject, in particular the Public Health Code.

HORUS PHARMA may collect the following data from you:

  • Identification data: last name, first name, phone number, email address, mailing address, source of the request, name of the person receiving the request, date of the request, description of the request, nature of the request, name of the product concerned.

3.5. PROCESSING FOR VIGILANCE PURPOSES

The processing operations implemented for vigilance purposes are intended to enable:

  • The implementation of vigilance as part of the monitoring of a product placed on the market (pharmacovigilance, medical device vigilance, nutrivigilance, biovigilance, cosmetovigilance), in particular through the recording, evaluation, and reporting of vigilance cases.

Data collection is based on compliance with the legal obligations to which HORUS PHARMA is subject.

HORUS PHARMA may collect the following data from you:

  • Identification data: last name, first name, initials, weight, gender, height, date of birth, phone number, email address, mailing address, identification number or alphanumeric code.
  • Identification data of the patient’s healthcare professional: last name, first name, phone number, fax number, email address, mailing address, specialty.
  • Sensitive data: personal or family history, risk factors, information regarding the method of prescription, associated diseases or events, nature of the adverse effect(s), test results, treatments administered.

    4. RETENTION PERIODS

Management of requests via the contact form 1 year from receipt of the requests
Web analytics and personalization of websites and mobile apps, cookie management 13 months
Statistical cookies 6 months
Marketing outreach 3 years from the last contact
Contractual relationships 5 years for the contractual relationship, 10 years for accounting, and 10 years for litigation 
Medical information 40 years
Pharmacovigilance 70 years after the date the drug, device, or product was withdrawn from the market

 5. INDIVIDUAL RIGHTS

In accordance with Regulation (EU) 2016/679 on the protection of personal data, you have the right to request from the data controller access to your personal data, the rectification or erasure of such data, and the restriction of the processing of your personal data. 

You also have the right to object to the processing of your personal data on legitimate grounds, as well as the right to object to the use of your data for direct marketing purposes.

Finally, you have the right to establish general and specific guidelines defining how you wish these rights to be exercised after your death.

If, after contacting us, you believe that your rights regarding your personal data have not been respected, you may file a complaint with the CNIL or the supervisory authority in your place of residence.

To exercise these rights or for any questions regarding the processing of your data in this system, you may contact our Data Protection Officer (DPO), providing proof of your identity.

To exercise your rights, you may contact the DPO:

By email: DPO@horus-pharma.fr

By mail: DPO HORUS PHARMA, Horus Pharma SAS, 22 Allée Camille Muffat, INEDI 5, 06200 Nice, France. 

6. RECIPIENTS

The recipients of your personal data are the relevant departments of HORUS PHARMA and its subcontractors within the scope of their duties.

This personal data is not disclosed to third parties. However, HORUS PHARMA reserves the right to disclose personal data to authorized third parties in order to comply with its legal obligations, particularly if required to do so by a court order.

For certain services, such as sharing on social media and cookies, our partners have access to your data.

HORUS PHARMA requires all its service providers and partners to process personal data in accordance with confidentiality and security commitments.

7. SECURITY

Taking into account technological developments, implementation costs, the nature of the data to be protected, and the risks to individuals’ rights and freedoms, HORUS PHARMA implements all appropriate technical and organizational measures to ensure the confidentiality of the personal data collected and processed and to provide a level of security appropriate to the risk.

HORUS PHARMA ensures the security of your personal data by implementing enhanced data protection through the use of physical and logical security measures.

HORUS PHARMA has established a personal data protection policy and informs any person acting under its authority who accesses this information of its confidential nature. In addition, HORUS PHARMA ensures that its technical service providers who may have access to personal data adhere to the same confidentiality standards.

However, it is the responsibility of each user to ensure the security of personal data transmissions over the internet. HORUS PHARMA cannot be held liable for the transmission of personal data over the internet.

8. TRANSFER OF PERSONAL DATA

Your data may be transferred to a country outside the European Economic Area. HORUS PHARMA has implemented the following safeguards to ensure an adequate level of protection for your information:

The transfer is governed, in accordance with the requirements of European Regulation No. 2016/679/EU of April 27, 2016, by:

  • Standard data protection clauses adopted by the European Commission: Commission Implementing Decision (EU) 2021/914 of June 4, 2021, on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council.

    9. SOCIAL MEDIA BUTTONS

You can share pages that interest you on social media by clicking on the share buttons.

The collection of information via social media share buttons is subject to the privacy policies of these third parties. We encourage you to read the policies of these social media platforms to understand how your personal data is used. 

10. COOKIES

Definition

Cookies are data stored on a user’s device and used by the website to send information to the user’s browser, allowing that browser to send information back to the originating website (for example, a session ID, language preference, or date).

Cookies allow status information to be retained, for the duration of the cookie’s validity, when a browser accesses the various pages of a website or when that browser returns to the website at a later time.

Only the issuer of a cookie can read or modify the information contained therein.

Several types of cookies may be used by the website:

  • Cookies strictly necessary for navigating the site and ensuring its proper functioning;
  • Cookies that enable the collection of traffic statistics;

Advertising content displayed on our website may contain cookies issued by third parties. Such cookies may also be placed on your device while you are browsing. The issuance and use of these cookies by third parties are subject to the privacy policies of those third parties.

Third-party cookies and trackers:

Consent

When you browse our website, the placement and reading of cookies allow us to analyze your browsing behavior and measure the audience of the www.horus-pharma.fr website.

You have the option to allow or block the placement of cookies used by our site that are not essential to its operation. They will only be placed if you consent to their use. To configure or change your settings at any time, you can use our cookie management tool.

If you configure your browser to reject cookies, certain features, pages, and sections of the site will not be accessible, for which we cannot be held responsible.

We also draw your attention to the fact that when you object to the installation or use of a cookie, an opt-out cookie is installed on your device.

If you delete this opt-out cookie, it will no longer be possible to identify you as having refused the use of cookies.

Similarly, when you consent to the installation of cookies, a consent cookie is installed. Consent or opt-out cookies must remain on your device. 

11. UPDATES

This policy takes effect on 11/30/2021.

To check for updates to our Policy, please visit this page regularly.

DO YOU HAVE ANY QUESTIONS?

The DPO at HORUS PHARMA is available to provide any additional information regarding the use of your personal data.

Please send your request by mail to: DPO HORUS PHARMA, HORUS PHARMA SAS, 22 Allée Camille Muffat, INEDI 5, 06200 Nice, France, or to DPO@horus-pharma.fr.