Privacy Policy

1.1 We are Alliance Pharmaceuticals Limited (referred to as “Alliance”, “we”, “us” and “our” in this Privacy Policy), a company incorporated in England with company registration number 03250064.

1.2 We are the data controller in relation to the processing of the personal data that you provide to us. We may also be the processor of your personal data. Our contact details are as follows:

1.2.1 Address: Company Secretary, Avonbridge House, Bath Road, Chippenham, Wiltshire SN15 2BB, United Kingdom

1.2.2 Telephone number: +44 [0]1249 466966

1.2.3 Email address: dataprotection@alliancepharma.co.uk (please include “Personal Data Request” in your subject heading to ensure it receives the correct attention).

1.2.4 If you are based in the EEA, please use the following email address: EUdataprotection@allianceph.com

1.3 You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

2.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

2.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, details of your qualifications, skills, experience and employment history.
• Contact Data includes delivery address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  
  

2.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

2.4 We will only process Special Categories of Personal Data where we are required to do so in order to fulfil our obligations in relation to (i) the reporting of adverse events communicated to us by you, other members of the public, your healthcare professional or pharmacists; (ii) the receipt of medical information enquiries from members of the public in relation to our products. For these purposes “Special Categories of Personal Data” shall mean: personal data revealing racial or ethnic origin and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

2.5 If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products). In this case, we may have to cancel a product you have with us but we will notify you if this is the case at the time.

3.1 Direct Interactions: We may collect personal information about you from a number of sources, including information you provide via our website, from telephone discussions with you (including call recording), from written information you have sent to us (including your CV) and from other communications. This includes personal data that you provide when you:

• subscribe to a service or publication;
• request marketing to be sent to you;
• apply for a position with us;
• enter a promotion or survey; or
• give us feedback, permit us to use your data in a testimonial or otherwise contact us.

3.2 Third parties or publicly available sources: We may also verify or correct your information from publicly available sources such as:

• the electoral register and Companies House (in the UK);
• healthcare/medical professionals’/researchers;
• “know your customer (KYC)” screening agencies;
• recruitment websites, such as LinkedIn; and
• search information providers (inside and outside the UK).

3.3 Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

3.4 Contact and Transaction Data from providers of technical, payment and delivery services.

4.1 We, or our business partners who act on our behalf, will use your data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where we need to comply with a legal obligation; and
• In relation to any medical issues, medical information enquiries or adverse events which you or your healthcare professional have reported to us, by email, in writing or via telephone via email; We process this information:
  • with your consent, or in your vital interests, in order to deal with the query or respond to the problem identified; and
  • to the extent we are legally required to keep records of the issues do so by any regulatory authority (including the Medicines & Healthcare products Regulatory Agency (MHRA)) in order to comply with a legal obligation to which we are subject.

4.2 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

5.1 Other members within the Alliance Group (where such members carry out functions which support the business of Alliance) will be entitled to use your personal data for any of the purposes set out in this privacy policy.

5.2 It may also be the case that we choose to share your data with third parties with whom we have business or marketing relationships from time to time for to use your personal data, for and on our behalf, for any of the purposes set out in this privacy policy. If you do not wish us to do this, please either: (i) tick the box when registering your details or on the order confirmation screen or (ii) make this clear in any writing or telephone communications with us which contain or would in accordance with this privacy policy lead to the collection of, any of your personal data.

5.3 We will also provide your personal data to the extent required by law or regulation to various legal and competent authorities including but not limited to:

5.3.1 Medicines & Healthcare products Regulatory Agency and/or the European Medicines Agency, in relation to our obligation to report any adverse events;

5.3.2 Her Majesty’s Revenue and Customs, in relation to any payments received by us for the sale of our products to third parties;

5.3.3 the police and other law enforcement agencies arising from any matters including counterfeit medicines;

5.3.4 Service providers, acting as processors, who provide IT and system administration services;

5.3.5 professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services; and

5.3.6 third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

5.4 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.1 We share your personal data within the Alliance Group. Where permitted by applicable law, we may transfer the personal data we collect about you to, or access or process it in or from, any of our group’s global locations from time to time.

6.2 Some of these countries may not be deemed to provide the same level of data protection as your home country as we deem necessary for the purposes set out in this privacy policy (Jurisdictions Pending Adequacy Rulings). If you are located in the EEA or UK, we have implemented a data transfer mechanism pursuant to Articles 46(2)(c) and (d) GDPR to secure the transfer of your personal data to Jurisdictions Pending Adequacy Rulings. Note that, due to these data transfer mechanisms, the same level of protection applies to data which is transferred to or accessed from any group global location.

6.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.

7.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

7.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

7.3 Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

As part of our business, we maintain stringent security measures designed to protect your personal data. This may include following certain procedures, physical or technological protection and may include encryption of data or asking you for proof of identity before we disclose your personal data to yourself.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will endeavour to ensure that the data we hold about you will be accurate and up to date. You can check the data that we hold about you by e-mailing us at the address above. If you find any inaccuracies in such data, please notify us and we shall delete or correct it promptly.

10.1 If you are based within the UK or the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you will have the following rights:

10.1.1 right to access: the right to request certain information about, access to and copies of the personal data about you that we are holding (commonly known as a data subject access request);

10.1.2 right to rectification: the right to have your personal data rectified if it is inaccurate or incomplete;

10.1.3 right to erasure/“right to be forgotten”: the right to withdraw your consent to our processing of the data (if the processing is based on your consent) and the right to request that we delete or erase your personal data from our systems (however, this will not apply if we are required to hold on to the information for compliance with any legal obligation or if we require the information to establish or defend any legal claim);

10.1.4 right to restriction of use of your information: the right to stop us from using your personal data or limit the way in which we can use it;

10.1.5 right to data portability: the right to request that we return any information you have provided in a structured, commonly used and machine-readable format, or that we send it directly to another company, where technically feasible; and

10.1.6 right to object: the right to object to our use of your personal data including where we use it for our legitimate interests or for marketing purposes.

10.2 If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

10.3 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We do not make decisions based solely on automated data processing, including profiling.

12.1 We also use "cookies" to gather information regarding the use of our site. A cookie is stored on your computer's hard drive by you and enables quick access to the site and provides us with certain information about your use of websites generally. You can amend the settings of your Internet browser to prevent automatic acceptance of cookies.

12.2 If you have given consent for us to do so, then we may from time to time use e-mail to contact you to notify you of new products or services, which we may from time to time supply. However, please contact us at any time by e-mail should you wish to change your decision either way.

12.3 For more information, please see our cookies policy found on this website.

We reserve the right to monitor all forms of communication whether electronic or otherwise with you for the purposes of development of the service and compliance with our policies and procedures. We may also use such monitoring to provide evidence of transactions which we have entered into with you.

14.1 We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.

14.2 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.