This Privacy Policy, corresponding to the website https://frezyderm.es (hereinafter, the “Website”) owned by Exeltis Healthcare, S.L., part of Exeltis Pharmaceuticals Holding S.L. (hereinafter, “Exeltis”), describes how Exeltis processes the personal data collected from users when they register or browse the Website (hereinafter, the “Users”).

We kindly ask Users to carefully read the following Privacy Policy as it contains important information about how we process the personal information they provide us with or that we collect through their browsing on the Website.

Exeltis and all its subsidiaries located in Spain, the European Union or third countries belong to the Insud Pharma Group (hereinafter, the “Insud Pharma Group”). For more information about the Insud Pharma Group or Exeltis subsidiaries, please click here. www.insudpharma.com.
Exeltis is committed to the privacy of its Users and the security of their data. We therefore undertake to use it in accordance with our legal responsibilities, in compliance with the General Data Protection Regulation (“GDPR”) and applicable local data protection regulations.

The identification details of the data controller and the Data Protection Officer are provided below:

Users may use most of the features of the Website without having to provide any personal data. However, for certain Website services or features, Users must provide us with their personal data in order to register for certain services and properly manage their requests. In addition to the information provided directly to Exeltis, we also collect certain information
when Users use our Website. All personal data collected through the Website will be duly incorporated into the databases managed by Exeltis. This processing is duly recorded in the Processing Activity Register.
We also inform Users that the fields marked with an asterisk (*) on the forms are obligatory. Therefore, if the requested information is not provided, we will not be able to provide the service. Below, we specify the personal data we collect, the purposes for which we use such personal data, and how long we will generally retain your personal data:

A. User communications and customer service
This category includes any personal data provided by Users in the course of their communications with Exeltis for the purpose of making or resolving any contact, incident or complaint. In this regard, if Users have made any request, query or suggestion through our contact forms or contact methods provided on the Website, we will process their personal data in order to respond to them

The legal basis for the processing of this personal data is the consent given by Users when they provide their data via the contact forms.

B. Pharmacovigilance enquiries
The information provided by Users through forms or spontaneously for the processing and management of notifications related to incidents involving products distributed by Exeltis will be processed by the Insud Pharma Group in order to comply with product monitoring and safety obligations, follow up on possible incidents, and resolve issues raised by Users.
If necessary, their data may be anonymously shared with the competent health authorities, marketing companies and product manufacturers, or other entities within the Insud Pharma Group.
The legal basis for the processing of this personal data is the consent that Users give us when they provide their personal data spontaneously or through the form provided for this purpose, and compliance with legal obligations regarding product safety and vigilance.

C. Information about access to and the use of our Website
We collect certain information from Users that is automatically obtained from their use of the Website, relating to their equipment or device, usage and browsing habits.
This information may include data such as the Users' language, pages, sections or features of the Website they use, IP address, search engine used, date and time, etc. Exeltis may collect this information through the use of cookies.

For more information on how we use cookies, please see our Cookie Policy.

We use this personal data based on our legitimate interest in improving our products and services, and the information is retained in accordance with the periods identified in each case in our cookie policy. For more information, please see our Cookies Policy.
Exeltis may enrich Users´ personal data with non-identifying information obtained from Users via the Website, as described above. In such cases, the combined information will be treated as personal data.

D. Website maintenance and optimisation

Users´ personal data will also be used in the maintenance and analysis of our Website, with a view to resolving performance issues, improving availability and protecting the Website against fraud (e.g., multiple login attempts) or non-compliance with our terms and conditions (e.g., use of the Website by persons under the age of 16). The analysis also allows us to check whether the various online services and processes we offer are working effectively so that we can improve them wherever possible.
The use of Users´personal data for these purposes is based on our legitimate interest and will be kept for the maximum period established in the Cookies Policy.

E. Compliance with our legal obligations
Users´ personal data may be disclosed to administrative authorities or courts in compliance with our legal obligations, or to protect the rights and safety of the Insud Pharma Group or our customers and employees.

On some occasions, it may be necessary to share Users´ personal data with other companies in the Insud Pharma Group or with third parties in order to guarantee the correct provision of a service requested or to ensure the proper functioning of the Website. We may share this information with the following entities:
Insud Pharma Group companies due to the use of shared computer systems, which may be
located in the European Economic Area (EEA) or in third countries.
Business partners and pharmaceutical laboratories that offer products jointly with Exeltis. Service providers, whenever necessary for the provision of a specific service.
These entities may be located in Spain, in other EEA countries, or anywhere else in the world. When we store personal data outside the EEA, we ensure that there is an adequate level of protection for the data transferred. We therefore require service providers to take appropriate measures to protect the confidentiality and security of personal data.
For example, for services provided by suppliers located outside the EEA, we use Standard Contractual Clauses approved by the European Commission.
We might also need to share personal info with the authorities to follow any legal requirements or court orders. All data communications will be carried out in compliance with current data protection regulations and, in particular, the GDPR.

Exeltis is committed to ensuring the security and confidentiality of its Users´ personal data. With this in mind, it has implemented appropriate technical, physical and organisational measures to protect personal data collected through the use of the Website from misuse, destruction, loss, alteration, disclosure, accidental, illegal or unauthorised acquisition or access, as required by the provisions of the GDPR and current data protection regulations.

That said, no website is totally secure, which means we cannot guarantee that your personal data will not be accessed by someone who is not authorised to do so. It is the responsibility of the Users to control the security of their information. To this end, Exeltis urges and encourages all Users to exercise caution when sharing information. Exeltis will not monitor the content and information that Users decide to share with other Users and, therefore, Exeltis is not responsible for the consequences of their actions.

Exeltis undertakes to act quickly and responsibly in the event that the security of Users´ personal data is compromised and to report such incidents, if applicable, with the utmost diligence.

Much of the information referred to in this Privacy Policy is collected through our use of cookies. Cookies are small text files containing small amounts of information that are downloaded and may be stored on Users' devices, such as computers, smartphones or tablets. These cookies are sometimes necessary to remember the User´s account settings, language and country, but they also allow us to measure and analyse User behaviour while they are using the Website and to show them personalised advertisements on our Website or on third-party websites.

When necessary, Users will be asked for their consent to the use of cookies. For further information, please read our Cookies Policy.

The Website is not intended for use by persons under the age of 16. Under no circumstances will we voluntarily collect personal data from persons under the age of 16.

Users may exercise their rights of access, rectification, erasure, objection, restriction of processing, and data portability, as well as withdraw their consent at any time, by contacting Exeltis, in accordance with the terms established in current legislation. This means that Users may request to know what data we hold about them, or update it, as well as request that Exeltis stop using the data for a specific purpose, or simply require that we delete all or some of their personal data from our files and databases.

If Users object to how their data is processed, Exeltis will stop processing it, except for legitimate reasons provided for in current regulations or to defend against possible claims.

After Users exercise any of these rights, and during the verification period by Exeltis, the data will remain blocked while certain circumstances are verified, and Exeltis will not be able to delete or process such data.

To exercise any of the rights described above, Users must contact Exeltis at the following email address: dataprotection@insudpharma.com, with the subject line ‘EXERCISE OF RIGHTS’ and indicating in the body of the email the specific right they wish to exercise. Furthermore, Users may also lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) or with the relevant data protection authority if they consider that their personal data has not been processed in accordance with the regulations.

Exeltis reserves the right to update this Privacy Policy at any time, at its sole discretion. The continued use of the Website by Users after any changes to this Privacy Policy implies acceptance of those changes.

We kindly request that Users review this Privacy Policy periodically so that they are aware of any changes to it. If Users do not accept this Privacy Policy, in whole or in part, or any of its amendments, they must refrain from using or accessing the Website, or immediately discontinue its use.

Should a User have any other questions about the use of their personal data or about our Privacy Policy, they can contact the Insud Pharma Group Data Protection Officer by sending an email to dataprotection@insudpharma.com.