What is the purpose and scope of this Privacy Policy?
The UPSA Hydrafizz website (https://upsa-hydrafizz.fr/) is intended to provide the general public with general information relating to our Hydrafizz range of products (hereinafter the “Site”).
Use of the Site is subject to this privacy policy detailed below relating to the processing of your personal data and respect for your privacy in accordance with Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and the free movement of such data (“GDPR”) and the Data Protection Act of 6 January 1978 as amended (hereinafter the “Privacy Policy”).
The Privacy Policy describes the different types of personal data that UPSA France (“UPSA” or “We”) collects and processes when you visit the Site, including emails, if any, that you exchange with us and/or communicate with us in this context and how we may use this data and with whom we may share it (collectively, the “Services”).
Our Privacy Policy also describes the measures we take to protect the security of your personal data. We also tell you how you can contact us to answer any questions you may have or to exercise your rights.
Changes to the Privacy Policy
We may update this Privacy Policy, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the “last updated” date, and take any other action required by applicable law. We therefore encourage you to review the Privacy Policy regularly. Please note, however, that the processing of your personal data based on your consent may not be modified or extended without your prior consent.
Acceptance of the Privacy Policy
All users of the Site must read this Privacy Policy carefully. If you do not agree to any of these terms, please do not access this Site and/or provide us with any personal data.
By accessing and browsing this Site, you declare that you fully understand, accept, and consent, without limitation, to this Privacy Policy.
Your access to and use of the Site, its subdomains and/or directories, its applications and functions, as well as all information or communications related thereto, including any emails sent via the Site, and more generally the Services, are governed by the Legal Notices and the General Conditions of the Site, this Privacy Policy, and all applicable laws and regulations.
What is personal data for the purposes of this Privacy Policy?
The term “Personal Data” as used in this Privacy Policy refers to any information or set of information that can identify you directly or indirectly, including by cross-referencing with other information (see paragraph below), in the context of your use of the Site.
UPSA’s access and/or use of any Personal Data concerning you in the context of the use of the Site is governed by this Privacy Policy.
What personal data about you do we process in connection with your use of the Site, on what basis, for what purpose and for how long?
Some of the information you submit to us as part of your use of the Site may constitute Personal Data.
All data and personal information you provide to us must be accurate.
You must therefore ensure that you keep all the information you provide to us up to date at all times. If applicable. In all cases, you are solely responsible for any false or inaccurate data or information you submit, as well as for any harm, loss, or damage caused to UPSA SAS or third parties as a result of the information, data, comments, opinions, or materials you have submitted.
Here are the cases in which you may be asked/required to provide Personal Data and on what legal basis and for what purposes we may use such information:
a) Data used in the context of the “Contact” section
If you contact our UPSA services at the telephone numbers indicated in the “Contact” section or through the contact forms that we make available to you on our Site, we may ask you to provide information that may sometimes be considered personal data, in order to enable us to respond to your questions and comments.
The legal basis for processing will in this case be your consent (in accordance with Article 6.1 a) of the GDPR).
The contact forms are kept in the back office of the Site for a period of thirty (30) days, in order to allow our UPSA teams to handle your requests. Your data is then kept by our teams for the time necessary to process your request and, where applicable, for an additional archiving period corresponding to the legal limitation period applicable in the event of litigation.
b) Data used in the context of sending UPSA information letters to pharmacies
As a result of their business relationship with UPSA, pharmacies are informed that they may receive emails containing institutional, commercial, or marketing information. In this context, the data processed are as follows: identity, email address, and opening and click data (for statistical purposes only).
These emails are sent exclusively to professionals, within the framework of UPSA SAS’s legitimate interest in communicating about its activities or products (in accordance with Article 6.1 f) of the GDPR).
As a pharmacist receiving these electronic communications, you can:
- You may first object to receiving these communications;
- and subsequently You can withdraw your consent at any time, either by clicking on the unsubscribe link at the bottom of each of our electronic communications, or by mentioning it to our pharmaceutical advisors or delegates or by writing an email to the following address: EUDPO@upsa-ph.com.
Your data will be kept for a period of three (3) years from the end of the pharmacy’s commercial relationship with UPSA SAS.
c) Personal data that we collect automatically:
During your visits to our Site, we may collect certain information such as the number of Internet users visiting our Site, the date of your last visit to the Site and the pages of the Site that you have consulted, mainly with a view to improving the quality of your visits or to allowing us to collect aggregated statistical information concerning all users of this Site.
This collection is carried out via “cookies” and “IP addresses”, essentially in order to measure the performance and audience of the Site where you share advertising content, under the conditions provided for by applicable law and regulations.
During your first visit to our Site, you will be asked to make your choices to consent, refuse, and/or configure your choices regarding the use of cookies, by displaying a dedicated banner.
You can then change your choices at any time (give or withdraw your consent, for example on certain cookies or all the cookies concerned) by reopening the cookie management banner, the link to which appears at the bottom of the Site page.
We draw your attention to the fact that, in accordance with the regulations, cookies necessary for the operation of the Site are not subject to your consent and therefore cannot be deactivated in this cookie management banner. You may object to this via your browser settings, but your experience on the Site may be degraded.
For complete information on the use of cookies and other trackers by UPSA and its partners, please consult our Cookie Policy section .
Who are the recipients of the personal data concerning you that we process in the context of your use of the Site?
The personal data concerning you that is communicated to us is intended exclusively for employees of UPSA SAS, its affiliated companies and its service providers who have a legitimate need to access it for the purposes of providing the Services or maintaining the operational condition of our platform and/or the Site and the Services. When these service providers and/or their potential subcontractors are not located in a country ensuring a sufficient level of protection of personal data, UPSA has implemented the necessary measures to guarantee an adequate level of protection of this data, for example through the implementation of standard contractual clauses of the European Commission.
We do not sell, rent, or trade the personal information you share with us in connection with the Services and use of the Site.
In addition, we may disclose information about you (i) if we are required to do so by law or court order, (ii) in response to a request from law enforcement or other government officials, or (iii) if we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity.
We reserve the right to transfer any information we hold about you if we sell or transfer all or a portion of our business or assets, to the extent and under the conditions permitted by applicable laws.
How do we protect your personal data?
We implement organizational, technical and physical safeguards to protect the personal data we collect and process through this Site against loss, unlawful use or unauthorized access, disclosure, alteration or destruction, in accordance with applicable laws and most commonly used practices.
Is your data subject to international transfers, particularly outside the European Union?
The tools used by UPSA for the purposes of managing and storing your personal data may result in the processing of your data outside the European Union, directly or indirectly by UPSA and/or its service providers.
In all cases where the processing of personal data concerning you would result in a transfer outside the European Union to a country which is not subject to an adequacy decision by the European Commission, UPSA will implement the necessary protection mechanisms as provided for by the Regulations applicable to the protection of personal data in order to ensure an adequate level of protection, in particular through standard contractual clauses approved by the European Commission or binding corporate rules in accordance with the state of European law and case law.
What are your rights regarding UPSA’s use of your personal data?
In accordance with the Regulations applicable to the protection of personal data, you have the following rights over your data:
- the right to object at any time to the processing of your data (when it has been collected on the basis of UPSA’s legitimate interest),
- the right to withdraw your consent at any time (when your data has been collected on the basis of the consent you provided to UPSA or to service providers and partners acting in its name and on its behalf),
- the right to ask us to correct, delete or restrict the processing of all or part of your data
- the right to ask us for a copy of the data concerning you that is processed by UPSA
- the right to ask us to transfer your data (or part of it) to other organisations under your right to portability, if applicable, and
- the right to provide instructions on the fate of your data after your death.
We may not be able to respond favorably to the exercise of your rights as mentioned above in the event that UPSA is required to retain them (i) under applicable law and regulations, (ii) to be able to comply with its legal obligations and to demonstrate, as necessary, compliance with these obligations to the competent authorities or (iii) to be able to demonstrate compliance with its contractual obligations.
How to exercise your rights?
To exercise these rights or for any questions about the processing of your data, each user can contact the Data Protection Officer (“DPO”) of UPSA SAS by email at the following address: EUDPO@upsa-ph.com or by post to the company’s headquarters, located at 3 rue Joseph Monier – 92500 Rueil-Malmaison.
Furthermore, if a user believes, after contacting UPSA SAS, that his or her rights are not respected or that one of the devices referred to above is being used in violation of the regulations applicable to the protection of personal data, he or she has the right to file a complaint with the National Commission for Information Technology and Civil Liberties (“CNIL”).
Would you like to contact us?
You may contact us at any time regarding these Terms:
- Any exercise of rights or request for information, in connection with the processing of your personal data, can be addressed to the UPSA Data Protection Officer at the following address: EUDPO@upsa-ph.com.
- For any further questions, please contact us:
- via the contact form.
- by mail: to the address 3 Rue Joseph Monier, 92500 Rueil-Malmaison cedex