Privacy Policy

1. Data protection at a glance

General Information

The following information provides a simple overview of what happens to your personal data when you visit our website. Personal data is any data that can be used to personally identify you. Detailed information on data protection can be found in our privacy policy listed below this text.

Data Collection on Our Website

The data processing on this website is carried out by the website operator. You can find their contact details in the imprint of this website.

How Do We Collect Your Data?

Your data is collected in part when you provide it to us. For example, this can be data you enter in a contact form or information that you provide when reporting side effects via this website. Other data is automatically collected by our IT systems when you visit the website. This includes technical data (e.g., internet browser, operating system, or time of the page visit). This data is collected automatically as soon as you enter our website.

What Do We Use Your Data For?

Part of the data is collected to ensure the error-free provision of the website. Other data may be used to analyze your user behavior.

What Rights Do You Have Regarding Your Data?

You have the right at any time to obtain free information about the origin, recipient, and purpose of your stored personal data. You also have the right to request the correction, blocking, or deletion of this data. For this, and for further questions on the topic of data protection, you can contact us at any time at the address provided in the imprint. You also have the right to lodge a complaint with the competent supervisory authority. Additionally, you have the right to request the restriction of the processing of your personal data under certain circumstances. For details, please refer to the privacy policy under “Right to Restriction of Processing.”

Analytics and Third-Party Tools

When you visit our website, your browsing behavior may be statistically analyzed. This is primarily done using cookies and so-called analysis programs. The analysis of your browsing behavior is usually anonymous; the browsing behavior cannot be traced back to you. You can object to this analysis or prevent it by not using certain tools. Detailed information about these tools and your options to object can be found in the following privacy policy.

2. General information and mandatory information

Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy. When you use this website, various personal data are collected. Personal data is data that can personally identify you. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this happens. We point out that data transmission on the Internet (e.g., communication by email) can have security gaps. A complete protection of the data from access by third parties is not possible.

Notice on the Responsible Party

The responsible party for data processing on this website is:

Responsible under the GDPR: Dipl.-Betriebswirt Stephan Huber
DENK PHARMA GmbH & Co. KG
Prinzregentenstraße 79
81675 Munich
Germany

Phone: +49 (0)89 23 00 29-0

Email: pharma@denkpharma.de

The responsible party is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g., names, email addresses, etc.).

Legally Required Data Protection Officer

We have appointed a data protection officer for our company: Andrew Ladouceur
microCAT GmbH
Bunsenstrasse 3
82152 Planegg-Martinsried
Phone: +49 89745158 64
Email: datenschutz@denkpharma.de

Revocation of Your Consent to Data Processing

Many data processing operations are only possible with your explicit consent. You can revoke an already given consent at any time. An informal email to us is sufficient for this purpose. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)

If the data processing is based on Art. 6(1)(e) or (f) GDPR, you have the right to object at any time to the processing of your personal data for reasons arising from your particular situation; this also applies to profiling based on these provisions. The respective legal basis on which the processing is based can be found in this privacy policy. If you object, we will no longer process your affected personal data unless we can demonstrate compelling legitimate grounds for the processing that outweigh your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims (objection according to Art. 21(1) GDPR).

If your personal data is processed to carry out direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling, insofar as it is related to such direct advertising. If you object, your personal data will subsequently no longer be used for direct advertising purposes (objection according to Art. 21(2) GDPR).

Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, particularly in the member state of their habitual residence, place of work, or the place of the alleged violation. The right to lodge a complaint is without prejudice to other administrative or judicial remedies.

Right to Data Portability

You have the right to receive the personal data concerning you, which we process based on your consent or for the performance of a contract, in a structured, commonly used, and machine-readable format. If you request the direct transfer of the data to another controller, this will only be done to the extent technically feasible.

Information, Blocking, Deletion, and Correction

Within the scope of applicable legal provisions, you have the right to obtain free information at any time about your stored personal data, their origin and recipients, and the purpose of data processing, as well as a right to rectification, blocking, or deletion of these data if applicable. For this purpose and for any further questions regarding personal data, you can contact us at any time using the contact information provided in the imprint.

Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time using the contact information provided in the imprint. The right to restrict processing exists in the following cases:

  • If you contest the accuracy of your personal data stored with us, we usually need time to verify this. During the period of verification, you have the right to request the restriction of the processing of your personal data.
  • If the processing of your personal data was/is unlawful, but you oppose the deletion of the data and instead request the restriction of their use.
  • If we no longer need your personal data for the purposes of processing, but you require them for the establishment, exercise, or defense of legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
  • If you have objected to processing pursuant to Art. 21(1) GDPR, a balance must be made between your interests and ours. Until it is determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.
Once you have requested the restriction of the processing of your personal data, these data may – aside from being stored – only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.

3. Data collection on our website

Cookies

Our websites partially use so-called cookies. Cookies do not harm your computer and do not contain viruses. They serve to make our offer more user-friendly, effective, and secure. Cookies are small text files that are stored on your computer and saved by your browser.

Most of the cookies we use are so-called “session cookies.” They are automatically deleted after your visit. Other cookies remain stored on your device until you delete them. These cookies enable us to recognize your browser on your next visit.

You can set your browser to inform you about the setting of cookies and to allow cookies only in individual cases, to exclude the acceptance of cookies for certain cases or in general, and to activate the automatic deletion of cookies when closing the browser. Disabling cookies may limit the functionality of this website.

Cookies that are necessary for the performance of electronic communication processes or for the provision of certain functions desired by you (e.g., shopping cart function) are stored based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in storing cookies for the technically error-free and optimized provision of its services.

If other cookies (e.g., cookies for analyzing your browsing behavior) are stored, they will be separately addressed in this privacy policy.

Inquiry via Email, Telephone, or Fax

If you contact us by email, telephone, or fax, your inquiry including all resulting personal data (name, inquiry) will be stored and processed by us for the purpose of handling your request. We do not pass on these data without your consent.

The processing of these data is based on Art. 6(1)(b) GDPR, provided your inquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on your consent (Art. 6(1)(a) GDPR) and/or on our legitimate interests (Art. 6(1)(f) GDPR), as we have a legitimate interest in the effective processing of inquiries directed to us.

The data you send to us via contact inquiries will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for data storage no longer applies (e.g., after completion of your request). Mandatory statutory provisions – especially retention periods under statutory law – remain unaffected.

4. Analysis tools and advertising

Paperturn

This website uses Paperturn, a service for creating and presenting digital flipbooks, to provide interactive content such as brochures, catalogs, or magazines on our website. When using Paperturn, various data may be collected, including IP addresses, usage data (e.g., access times and how often a specific flipbook is viewed), and device data (e.g., browser type and version). The data collected is processed by Paperturn to analyze the use of the flipbooks and optimize their functionality. Paperturn may also use this data to provide statistical evaluations for us. For more information on data processing by Paperturn and Paperturn’s privacy policy, please visit: https://www.paperturn.com/de/rechtsportal/dsgvo-und-paperturn You have the right to object to data processing by Paperturn. Further information on your rights can be found in our general privacy policy. We have concluded a data processing agreement with Paperturn in accordance with Art. 28 GDPR to ensure that Paperturn processes data on our behalf and in accordance with applicable data protection regulations. The information collected by Paperturn may be transferred to countries outside the European Union. Paperturn has implemented adequate safeguards to ensure compliance with the European data protection level.

Google Tag Manager

This website uses Google Tag Manager. Google Tag Manager is a solution that allows us to manage website tags through an interface. The Google Tag Manager itself (which implements the tags) does not process personal data of users. With regard to the processing of users’ personal data, reference is made to the following information on Google Analytics 4.

Google Analytics 4

This website uses Google Analytics 4, a web analytics service provided by Google LLC (“Google”). The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and enable an analysis of your use of the website. The information generated by the cookies about your use of this website is usually transmitted to a Google server in the USA and stored there.

The storage of Google Analytics cookies and the use of this analysis tool are based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in analyzing user behavior to optimize both its web offering and its advertising.

IP Anonymization

We have activated the IP anonymization feature on this website. This means your IP address will be truncated by Google within member states of the European Union or other parties to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be sent to a Google server in the USA and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, compile reports on website activity, and provide other services related to website usage and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics 4 will not be merged with other Google data.

Browser Plugin

You can prevent the storage of cookies by adjusting your browser software settings accordingly; however, please note that if you do this, you may not be able to use all features of this website to their full extent. You can also prevent Google from collecting and processing data generated by cookies related to your use of the website (including your IP address) by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

Objection to Data Collection

You can prevent Google Analytics from collecting your data by clicking on the following link. An opt-out cookie will be set to prevent the collection of your data on future visits to this website: Disable Google Analytics 4.

For more information on how Google Analytics 4 handles user data, please refer to Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=en.

Data Processing

We have signed a data processing agreement with Google in accordance with Art. 28 GDPR and fully implement the strict requirements of German data protection authorities when using Google Analytics 4.

Demographic Features with Google Analytics 4

This website uses the “demographic features” of Google Analytics 4. This allows reports to be generated containing information about the age, gender, and interests of website visitors. This data comes from Google’s interest-based advertising and visitor data from third-party providers. This data cannot be attributed to any specific individual. You can disable this feature at any time through your Google account’s ad settings or generally prevent Google Analytics from collecting your data as described in the “Objection to Data Collection” section.

Data Retention

Data stored by Google at the user and event level linked to cookies, user identifiers (e.g., User ID), or advertising IDs (e.g., DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 14 months. For more details, please visit the following link: https://support.google.com/analytics/answer/7667196?hl=en.

5. Plugins and Tools

YouTube

Our website uses plugins from the YouTube site operated by Google. The operator of the pages is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. When you visit one of our pages equipped with a YouTube plugin, a connection to the YouTube servers is established. This informs the YouTube server about which of our pages you have visited.

Furthermore, YouTube may store various cookies on your device. With the help of these cookies, YouTube can receive information about visitors to our website. This information is used, among other things, to collect video statistics, improve user-friendliness, and prevent fraud attempts. The cookies remain on your device until you delete them. If you are logged into your YouTube account, you enable YouTube to directly associate your surfing behavior with your personal profile. You can prevent this by logging out of your YouTube account. The use of YouTube is in the interest of an attractive presentation of our online offers.

This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. For more information on how user data is handled, please refer to YouTube’s privacy policy at: https://policies.google.com/privacy?hl=en.

hCaptcha

We use hCaptcha (hereinafter referred to as “hCaptcha”) on this website. The provider is Intuition Machines, Inc, 2211 Selig Drive, Los Angeles, CA 90026, USA (hereinafter referred to as “IMI”).

The purpose of hCaptcha is to check whether data is entered on this website (e.g. in a contact form) by a human or by an automated program. For this purpose, hCaptcha analyzes the behavior of the website visitor based on various characteristics.

This analysis begins automatically as soon as the website visitor enters a website with activated hCaptcha. For the analysis, hCaptcha evaluates various information (e.g. IP address, time spent on the website by the website visitor or mouse movements made by the user). The data collected during the analysis is forwarded to IMI. If hCaptcha is used in “invisible mode”, the analyses run completely in the background. Website visitors are not informed that an analysis is taking place.

The data is stored and analyzed on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in protecting its website from abusive automated spying and SPAM. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TDDDG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

Data processing is based on standard contractual clauses contained in the data processing addendum to IMI’s General Terms and Conditions or the data processing contracts.

Further information about hCaptcha can be found in the privacy policy and terms of use at the following links: https://www.hcaptcha.com/privacy and https://hcaptcha.com/terms.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA, which is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/list.

6. Privacy Information in the Field of Pharmacovigilance

Below, we explain to you the data processing of Denk Pharma GmbH & Co. KG when you report an adverse drug reaction (side effect) to us.

Purpose of Data Collection

Reports of adverse drug reactions are of great importance to public health and help in the detection, assessment, understanding, and prevention of adverse drug reactions or other issues related to medications. By reporting adverse drug reactions, you can contribute to gathering and providing more information about the safety of a medication. Therefore, Denk Pharma GmbH & Co. KG appreciates every report concerning our products. Denk Pharma GmbH & Co. KG collects data on reports of adverse drug reactions or other information relevant to pharmacovigilance for a product, in accordance with the legal requirements of the European Union or the respective country of origin of the report. The legal basis for the collection of this data is Article 6(1)(c) of the EU General Data Protection Regulation (EU GDPR). For transfers outside the EU, Articles 6(1)(f) and 49(1)(e) of the EU GDPR continue to apply.

What Information Do We Collect?

The following personal data is collected on a voluntary basis from patients:

  • Name/Initials
  • Date of birth/Age
  • Gender
  • Country
  • Details of the adverse drug reaction
  • Information about the Denk Pharma product, including reason for use, period of use, and dosage.
  • Additional information about medical history voluntarily provided to us
  • Contact details for inquiries (such as address, telephone number, email address, fax)

The full name (except initials) and contact details are anonymized or deleted as soon as they are no longer necessary for further processing of the report. The following personal data is collected on a voluntary basis from sources reporting adverse drug reactions, e.g., healthcare professionals:

  • Name/Initials
  • Profession
  • Contact details for inquiries (such as address, telephone number, email address, fax)

The mentioned information is collected by the pharmacovigilance department of Denk Pharma GmbH & Co. KG and protected from unauthorized access.

Use and Disclosure of Data to Third Parties

The personal data you provide will be used in accordance with applicable regulatory and legal requirements to maintain the high standards of quality and safety of the medicinal products distributed by Denk Pharma GmbH & Co. KG. Additionally, it serves to fulfill Denk Pharma GmbH & Co. KG’s legal or regulatory obligations to report adverse drug reactions to regulatory authorities.

If you have consented to further contact, we may record your contact details to request additional information from you regarding the reported adverse drug reaction.

In some cases, we are obligated to report information relevant to drug safety (e.g., reports of adverse drug reactions) to health authorities worldwide, including countries with data protection standards different from those of the EU. This may also necessitate sharing the information with local representatives of Denk Pharma GmbH & Co. KG. Reports of adverse drug reactions contain detailed information about the reported adverse drug reaction, but only limited personal data:

Patient data included, depending on available information:

  • Age
  • Date of birth / Year of birth
  • Gender
  • Initials (but not the full name of the patient)

Data of the reporter, depending on available information:

  • Name or initials
  • Professional activity (e.g., physician, pharmacist)
  • Contact details / Address

If the reporter does not wish to provide their data to the authorities, the fields in the report to the authority will be masked.

When your data is transferred to local representatives outside the EU, we ensure appropriate protection of personal data.

Retention Period of Data

Denk Pharma GmbH & Co. KG retains your personal data for as long as necessary to fulfill our legal obligations or to assert, exercise, or defend legal claims. As the reporting of adverse events is important for public health reasons, the reports must be kept for at least 10 years after the authorization for the product concerned has expired. 

Right to Information, Correction, and Deletion of Your Personal Data

You can contact Denk Pharma GmbH & Co. KG at any time to find out what data we have stored about you and for what purposes. In justified cases, you can also request the deletion, correction, or restriction of the processing of your personal data. If such a request would require Denk Pharma GmbH & Co. KG to violate applicable laws or regulations, Denk Pharma GmbH & Co. KG may not be able to fully comply with the request. In this case, the processing of the data will be restricted to legally necessary activities.

You also have the right to object to the processing of your personal data, including transfer to authorities outside the EU, unless the interests of Denk Pharma GmbH & Co. KG take precedence.

If you have questions regarding our use of personal data in pharmacovigilance or about this privacy policy, or if you wish to exercise your rights, you can contact us at any time: pharma@denkpharma.de Alternatively: datenschutz@denk-products.de

For processing of your personal data covered by EU law, if you have questions or concerns about data processing, you can also contact the relevant data protection authority: Der Bayerische Landesbeauftragte für den Datenschutz Bayern, Postfach 22 12 19, 80502 München, poststelle@datenschutz-bayern.de

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