Politique de confidentialité

Effective date: 21 December 2019

Thank you for visiting our website. Pharmony respects your privacy. When it comes to your personal information, we believe in transparency, not surprises. That is why we specify here the personal information we collect, what we do with it, and your choices and rights.

The Belgian company PHARMONY SPRL (hereinafter: “we, us, our” or “Pharmony”), whose registered office is located at 2, Avenue d’Ecolys, 5020 Namur, Belgium and which is registered with the ECB under number 0830.310.102, acting as data controller, processes and uses personal data relating to our prospects, customers, job applicants, partners and suppliers, as well as visitors to our website https://pharmony.be (hereinafter collectively referred to as the “Customers”), in accordance with applicable data protection regulations, in particular European Regulation no. 2016/679 of 27 April 2016 known as the General Data Protection Regulation (hereinafter referred to as the “GDPR”).

The purpose of this privacy policy (“Policy”) is to explain how and why our company collects personal data about our Customers (“Customer Data”), what Customer Data is collected/processed, where this data comes from, who has access to it, to whom this data may be transferred, how long it is kept, how Pharmony protects it and what the rights of Customers affected by the processing are. This notice is without prejudice to specific provisions contained in other documents, if any.

If you have any questions or requests regarding our Policy or the way we handle your data in general, please contact us via section 14 below.

1. Why does Pharmony process Customer Data?

Pharmony stores and processes Customer Data, whether in electronic or non-electronic form, for administrative, marketing and customer management purposes, in particular in light of the following non-exhaustive activities:

  • Processing and responding to any communication, request or query that Customers submit to Pharmony or following initial contact with Pharmony (including via the website: “contact” or “book a demo” tabs),

  • Process information relating to the sale (actual or potential) of Pharmony products and/or services (including via the website: “contact form” to be completed),

  • Send invoices to Customers,

  • To provide Customers with information and other marketing communications such as newsletters,

  • Conducting surveys and market studies

  • Improve Pharmony products and/or services, including our website

  • Resolve potential conflicts.

2. What are the legal grounds for processing Customer Data?

Customer Data is processed on the basis of one or more of the following legal grounds:

  • For the conclusion and execution of a sales contract with a Customer, including the invoicing procedure,

  • In order to comply with the legal obligations applicable to Pharmony (e.g. article 67, §2, paragraph 3 of the law of 18 September 2017 on the prevention of money laundering and the financing of terrorism and on the restriction of the use of cash),

  • Within the framework of the legitimate interests of Pharmony and/or a third party but which, in the opinion of Pharmony, also benefit Customers, such as, but not limited to, direct marketing and data analysis,

  • The consent of the Customer concerned (e.g. to answer a survey). The Client concerned may withdraw his consent at any time, it being understood that such withdrawal will not affect the lawfulness of the processing carried out prior to such withdrawal on the basis of such consent.

3. What categories of Customer Data are processed?

Customer Data is any personal and business information about an identified or identifiable natural person.

For the above-mentioned purposes, the processing of personal data may include the following categories:

  • Personal identifying information, such as name,

  • Personal details, such as age, language, nationality, gender, occupation,

  • Photos and audio-visual recordings,

The processing of professional data may include the following categories:

  • Professional identification data, such as the address

  • Electronic identification data, such as e-mail address and telephone number

  • Financial data, such as payment method information

  • Connection data, such as IP address,

  • Survey data.

4. Where does the Customer Data come from?

When a Customer contacts Pharmony, the initial data generally comes from that Customer. Pharmony may also contact a Customer for canvassing purposes. As part of the relationship with a Customer, the latter will provide Pharmony with additional information (e.g. information required to place an order). If the Customer does not provide Pharmony with the information required by law or the contract, the Customer may lose benefits or Pharmony may decide not to conclude the contract or even terminate it. For example, if a Customer does not wish to share his/her e-mail address with Pharmony, he/she will not receive any newsletters from Pharmony.

Pharmony may also receive data about the Customer from other customers, or from suppliers or those with whom the Customer communicates by e-mail or other systems.

5. Who has access to Customer Data?

For the above-mentioned purposes, personal data may be disclosed to, and possibly processed by :

  • the Clients themselves;

  • Pharmony staff;

  • individuals and legal entities, who have direct contact with Pharmony ;

  • public authorities in accordance with the applicable regulations (including tax administration, judicial and police authorities) ;

  • IT service providers ;

  • providers of online payment services;

  • banks and insurers;

  • our professional advisers

  • our business partners ;

  • our marketing service providers; and

  • analysis and search engine providers who help us to improve and optimise our website, such as Google Analytics.

We will also disclose information to third parties:

  • in the event of a purchase or sale of a business or assets, we reserve the right to disclose your business and personal information to the seller or buyer of such business or assets;

  • In such transactions, if Pharmony or all of our assets are purchased by a third party, customer information will be one of the transferred assets;

  • if we are obliged to disclose or share your data to comply with a legal obligation or to protect the rights, property or safety of Pharmony, our customers or others. This includes sharing information with public authorities (including judicial and police authorities) in the event, for example, of a cyber incident.

6. Is Customer Data transferred abroad?

This data is generally kept in Belgium, but we may transfer certain data abroad in connection with Pharmony’s activities. If a data transfer is carried out outside the European Union, Pharmony will have put in place appropriate guarantees in line with the RGPD.

Pharmony never resells Customer Data.

7. How long is Customer Data retained?

Customer Data will not be kept longer than necessary for the above-mentioned purposes. Typically, and subject, on the one hand, to what would otherwise be provided for in other documents in this respect concerning specific data, and/or, on the other hand, to the exercise by Customers of their rights of opposition or withdrawal of consent, Customer Data will be retained for the duration of the operation of our products and services, as well as after the termination of our products and services, for as long as Pharmony may have a legal liability for which the use of Customer Data may be relevant, taking into account applicable limitation periods and legal retention obligations.

The contact data will be used to keep the Clients concerned informed of Pharmony’s activities as long as they do not object.

8. How is Customer Data protected?

Pharmony retains Customer Data to protect it, as far as reasonably possible, against loss and unauthorised disclosure or access. Pharmony nevertheless draws Customers’ attention to the fact that no absolute guarantee of security, particularly on the Internet, can be provided.

If you would like to learn more about the transfer of your information and/or the safeguards implemented (including how to obtain a copy), please contact us using the contact details in section 14 below.

9. What are the rights of individuals and who can they contact?

Individuals whose personal information is collected and processed as Customer Data have, at any time and provided they provide sufficient proof of their identity, the right to contact Pharmony, if they wish to do so:

  • Access, correct or delete their personal data,

  • Restricting or objecting to their processing (e.g. for direct marketing purposes),

  • Receive the data they have provided, in a structured, commonly used and machine-readable format, and transmit them to another controller if they so wish, where such data have been processed on the basis of their consent and/or for the performance of the contract,

  • Receive additional information on safeguards for international data transfers,

  • File a complaint with the Belgian Data Protection Authority (rue de la presse 35, 1000 Brussels, contact@apd-gba.be) or another supervisory authority of the European Union if they consider that Pharmony has not acted in accordance with the applicable data protection regulations.

The contact person within Pharmony for any further information concerning these rights is :

+32 78 48 17 17

10. Cookies

Pharmony uses “cookies” to improve the functioning of its website and to collect statistical information.

What are cookies?

A cookie is a small text file that may be stored on your computer when you visit websites. Information is stored in this text file, such as your choice of language for a website. When you visit the website again later, this cookie is sent back to the website in question. In this way, the website recognises your browser and can, for example, remember your choice of language.

Les cookies usually also have an expiry date. For example, some cookies are automatically deleted when you close your browser (so-called session cookies), while others remain on your computer for longer, sometimes even until you delete them manually (so-called permanent cookies).
Cookies that are not necessary to make the services available on our website (e.g. statistical cookies) are only used when we receive your consent, which you express through the warning message on our website.

How do I disable cookies?

It is possible to configure your browser to prevent the use and storage of cookies on your device and/or that you are asked each time you visit the site to enable cookies. You can also, at any time, delete cookies that have been reactivated. Consult the help section of your browser to find out how to do this. Please note that disabling cookies globally may cause malfunctions on our site.

What cookies do we use?

The table below details the cookies used on the Pharmony website and the cookies used by third parties of which the Pharmony website is aware.

Please note that other third parties (e.g., external service providers such as Facebook or MailChimp) may also use cookies over which we have no control. These cookies are most likely to be analytical/performance or targeting cookies.

11. Data on children

Our website is aimed at pharmacies. Pharmony therefore does not knowingly collect personally identifiable information from children under the age of 13.

If a parent or guardian knows that their child has provided personal information to Pharmony, contact the “PRIVACY OFFICER”.

If Pharmony becomes aware that it has collected personal information from a child under the age of 13, Pharmony will take steps to delete this information from our servers.

12. Amendments

Pharmony may amend this Privacy Policy at any time when necessary, in particular to comply with changes in regulations or requirements introduced by data protection authorities.

Pharmony will inform its Customers of any changes by posting the new Policy on its website. Pharmony also recommends that its Customers regularly consult this Policy.

Changes to the Policy are effective upon posting on the Website.

13. How to contact us?

If you have any questions, comments or requests regarding this Policy, they may be addressed in writing to the following address: Pharmony SPRL, for the attention of the “PRIVACY OFFICER”, 2, Avenue d’Ecolys, 5020 Namur, Belgium or by email to dataprivacy@pharmony.be.