• GENERAL

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This Privacy Policy describes how Chemo Research, S.L.  (hereinafter, “Chemo”) manage and process the information collected from you (the “User”) when navigating through the website www.stec-husstudy.com/ (hereinafter, the “Website”), owned by Insud Pharma and manage by Chemo. Please read carefully this Privacy Policy as it contains important information concerning the personal data of Users and how we use it.

Chemo and all its subsidiaries located in Spain, EU or third countries are globally known as Insud Pharma group (hereinafter, “Insud Pharma Group”). Please find additional information about Insud Pharma Group here.

Chemo dedicates all its efforts to respect the privacy and security of the Users and undertakes to use personal data in accordance with the General Data Protection Regulation ("GDPR") and national data protection law.
The identification of the data controller and the data protection officer are the following:

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• Corporate Name: Chemo Research, S.L.

• Registered office: Calle Manuel Pombo Angulo, 28 3ª planta 28050 Madrid, España.

• Tax Identification Number: B-86315231

• Telephone: +34 917711500

• Email: dataprotection@insudpharma.com

•  Companies House Information: Commercial Registry of Madrid, Page M-566584, Volume 31.477, Sheet 70

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• CATEGORIES OF PERSONAL DATA AND PURPOSES OF THE PROCESSING

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Users may use some functionalities of the Website without having to provide Chemo any personal data. However, for certain functions, Users shall provide personal data in order to manage their requests or provide the information of their interest. In addition to the information you provide directly to Chemo, we collect certain information when you visit our Website.

Personal data collected through the Website will be duly incorporated in databases under the responsibility of Chemo which will be registered in Chemo record of processing activities.

Below, we have specified the categories of personal data we collect, the purposes for which we use such data and how long we will keep the personal data:

 

• Users Communications and Requests

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The Website integrates WhatsApp messaging to allow Users to contact and be connected with Chemo. Through this application, Users can contact Chemo and communicate their queries in relation to the information provided on the Website. Chemo will process the User's personal data that may be provided through this way, or in subsequent communications through other communication channels enabled, in order to meet and resolve their requests, contact or send the information requested by the User. The personal data processed in these cases may include, mainly, name, telephone number and other information that the User may include in his query.

The communication channels provided by Chemo on the Website are not intended to collect or process health-related data or information. Under no circumstances will Chemo ask Users to provide medical information of third parties, or to attach documents that may be considered special categories of data or sensitive data under the current data protection regulations. It will be the ultimate responsibility of the Users to comply with data protection regulations and the duty of secrecy when sharing information with Chemo through this messaging application. The User shall guarantee and be responsible for collecting the express consent of individuals/data subjects in order to communicate their contact details to Chemo.

For the fulfilment of this purpose Chemo may engage third services providers to ensure the confidentiality and privacy of users when managing and solving their requests. In any case, these third entities shall act as data processors and shall follow Chemo’s instructions when accessing to personal data of users. 

The legal basis for the processing of these personal data is the legitimate interest of Chemo for the management of request and queries forwarded by Users through the Website. 

 

• Information About the Use of Our Website 

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Chemo collects information automatically obtained by the Website related to the identification of the User’s computer equipment, use and navigation habits. 

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Said information includes data regarding language, pages or sections of the Website, keywords, date, time, amount of time the User expends in certain types of webpages, which section of the page he has visited, and similar information related to the use of the Website. Chemo may collect this information using cookies. To obtain additional information please visit our Cookies Policy.

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We use this personal data based on our legitimate interest in order to improve our services and User’s experience on the Website, as well as based on the consent shown by the User through cookies settings. We will keep the Personal Data for the period set forth in the Cookie Policy of the Website.

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Chemo may combine your personal data with other information provided by the User or collected from the Website as above mentioned. In those cases, all combined information will be processed as personal data during the period the information remains combined.
 

• Website Maintenance and Optimization
   

Users' personal data will also be used for the maintenance and analysis of our Website, solve any problem, improve availability and protect the Website against fraud (e.g. in case of repeated log attempts or non-compliance with our terms and conditions, e.g. by persons under the age of 16). Analytics also allow us to check whether the online services we offer work effectively in order to improve them whenever possible. 

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The use of User's personal data for these purposes is necessary based on our legitimate interest and will be retained for the period set forth in the Cookie Policy of the Website.

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• Comply with our Legal Obligation

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We may need to process your personal data to comply with legal obligations binding or accepted by us. Likewise, we may need to provide information to and as required by local law enforcement agencies, other government authorities, or otherwise required by law or to protect the rights and safety of our property, company, employees and customers.

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• How We Share Personal Data

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Sometimes it is necessary to share your personal data with third parties in order to guarantee the correct provision of the services. We may share such information with the following:​

 

• 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. 

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• Service providers, acting as data processors, to the extent necessary for the provision of a service. In particular, Chemo has engaged Women Hub, S.L. for the correct management and response to requests submitted through the Website as well as, if required, to contact Users to provide them with information requested.

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• Competent authorities: in case of legal requirement or obligation, as well as for the defence and exercise of rights, it may be necessary to communicate data to the competent authorities in each case.

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Such entities may be located in Spain, other countries in the EEA or anywhere else in the world. When we keep personal data outside the EEA, we guarantee an adequate level of protection of the transferred data. To this purpose, we require service providers to take appropriate measures to protect the confidentiality and security of personal data.

For example, for services provided by providers outside the European Economic Area, we use Standard Model Clauses approved by the European Commission.

Chemo may disclose User’s personal data to any public administration, when required by law and compelled to do so by such authorities. All data communications will always be carried out in compliance with the GDPR and the national data protection law.
 

• Retention of Personal Data

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We will keep your personal data for as long as it is necessary to fulfil the purposes described in this Privacy Policy. In any case, in the event Users have granted their consent, their personal data will be kept as long as they do not withdraw the consent previously granted. 

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Personal data collected through the use of cookies will be kept for the period of time indicated in the Cookie Policy. Once these periods have expired, personal data will be deleted.

 

• Security

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Chemo cares to ensure the security and confidentiality of the Users personal data. Therefore, we have taken several security measures and technical means to prevent the loss, misuse or access to the personal data without the User permission in accordance with GDPR and the national data protection law.

Nevertheless, it is also the User responsibility to control his or her personal information, therefore Chemo asks and encourages all Users to be careful sharing information and content. Chemo shall not control the content and information the User chooses to share with other Users and, therefore, Chemo is not responsible for the consequences of the Users own actions.

Chemo pledges (i) to act rapidly and in a responsible manner in the event the Users personal data security is deemed at risk, and (ii) to report it if relevant with the greatest diligence.

 

• Cookies

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Much of the information referred to in this Privacy Policy is collected through the use of cookies. Cookies are small text files containing small amounts of information that are downloaded and can be stored on your user device, for example, your computer, smartphone or tablet. 

These cookies are sometimes necessary to remember your account settings, language and country, but they also allow us to track and analyse Users behaviour on our Website and to display personalised advertisements on our Website or on third party websites. Where necessary, you will be asked to consent to the use of cookies. To obtain additional information on how cookies are used in the Website and its deactivation please visit the Cookies Policy.

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• Minors 

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The Website is not intended to be used by persons under the age of 16. Under no circumstances Chemo will voluntarily collect personal data from persons under the age of 16.
 

• Users Rights Concerning Data Protection

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At any time, Users may exercise before Chemo their data protection rights, in particular the right of access, rectification, restriction of processing, erasure, objection and portability pursuant to the applicable legislation. This means Users can ask what personal data we have about them, update, or they can request that Chemo stops using data for a specific purpose, or simply require Chemo to delete all personal data from our files and databases among other.

In the event the User decides to object to the processing of the personal data, Chemo will no longer process personal data in connection to such User. Personal data may still be processed for the purposes established in data protection legislation or bring defence against legal claims.

After the User exercises any of the abovementioned rights, and during Chemo verification period, all personal data will be kept blocked. The blocking procedure will prevent Chemo from processing or erasing such personal data.

For the exercise of any of the abovementioned rights, the User shall contact Chemo by email, addressing the request to dataprotection@insudpharma.com indicating as reference: “EXERCISE OF RIGHTS” and identifying the right to be exercised. In addition, Users may also lodge a claim before the Spanish Data Protection Agency (www.aepd.es) or the relevant data protection authority if they consider that we have not processed their personal data in accordance with the regulations.

 

• Privacy Policy Updates

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Chemo reserves the right, at our sole discretion, to modify or replace this Privacy Policy. Your continued use of the Website after any such changes constitutes your acceptance of the new Privacy Policy.

Please review this agreement every so often in order to acknowledge any possible modifications. If you do not accept this document, partially or as a whole, or any subsequent modification, please refrain from the use, access or continue to access the Website or discontinue any use of the Website immediately.

 

• Contact

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If you have any further questions about the use of your personal data or about our Privacy Policy, you can contact Chemo Data Protection Officer by email through dataprotection@insudpharma.com