Privacy

1. General

In the framework of this Website Privacy Policy (the “Privacy Policy”), “Personal Data” means any personal data as defined in Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data of 14 April 2016 (the “GDPR”), as well as the applicable national implementing or additional legislation (collectively the “Data Protection Legislation”), i.e. any information relating to an identified or identifiable individual.

This Privacy Policy explains how Will-Pharma SA (“WILL”) collects, processes, uses and protects certain Personal Data related to you when you use the WILL’s websites www.willpharma.comwww.cogniton.bewww.combizym.bewww.vitamine-c-will.be,www.medicamentcontreleshemorroides.be, and  www.willocare.be, as well as any website owned or otherwise controlled by WILL that refer to this Privacy Policy (collectively the “Websites”).

For the avoidance of doubt, it is expressly understood that the Privacy Policy applies to the website www.willpharma.com (the “Dutch Website”) owned and managed by Will-Pharma Nederland B.V. with registered offices at Wilgenlaan 5, 1161 JK Zwanenburg (The Netherlands).

Except when provided otherwise in this Privacy Policy, (i) the Dutch Website shall be included under the term Websites and (ii) WILL shall also refer to Will-Pharma Nederland B.V..

WILL respects your privacy and the way that you choose to provide data. WILL recognizes the need for appropriate protection and management of Personal Data collected. WILL conducts its business pursuant to this Privacy Policy and assists you in understanding what types of Personal Data WILL may collect, how that Personal Data may be used, and with whom the Personal Data may be shared as the case may be.

WILL processes your Personal Data in compliance with this Privacy. By accessing, visiting or otherwise using the Websites, you fully and unconditionally consent to the application of this Privacy Policy and you authorize WILL to process your Personal Data in accordance with and for the purposes defined therein. This Privacy Policy is accessible on the Websites.

2. Controller

The legal entity responsible for the processing of your Personal Data is Will-Pharma SA, having its registered offices at Rue du Manil 80, B-1301 Wavre (Belgium), registered with Crossroads Bank for Enterprises under company number 0402.018.775.

 

  • Offices Luxemburg:

Rue du Merschgrund 54 - L8373 Hobscheid (Habscht)

Phone: +352 (0)45 09 86

Fax: +352 (0)45 09 87

Email:willpharma@willpharma.com

With respect to the Dutch Website, the entity responsible for the processing of Personal Data is

  • Offices The Netherlands:

Will-Pharma Nederland B.V.

Wilgenlaan 5, 1161 JK Zwanenburg

Phone: +31 (0)20 497 65 51

 

3. Categories of Personal Data processed

WILL collects your Personal Data in the framework of the provision of the Websites and your use thereof, pursuant to this Privacy Policy. The Personal Data collected and processed by WILL encompass the following information:

3.1 General

 

  • Personal Data related to your use of the Websites (“Browsing Data”): ID of the device you use to access the Websites (MAC address); IP address; data on how, when and for how long you access and use the Websites; the sub-websites which are reached via an access to the Websites; your Internet service provider; information related to your operating system, the type and version of your browser and device; searched items and and/or consulted pages on the Websites.

 

  • Personal Data that you provide when asking a question or otherwise contacting WILL via the online “contact form”: your first and last names, email address, the content of your message and, optionally, the company to which you belong and your phone number (“Request Data”).

 

  • Profile Data”: on the basis of the Browsing Data, WILL will create and store user marketing profiles.

The Browsing Data will be collected via the connection between your device (computer, smartphone or tablet) and WILL’s web server. The Profile Data will be created by an analysis of the Browsing Data by WILL.

3.2 Job Application

You can decide to apply for a job at WILL, whether for a vacant position or spontaneously, by sending an email with your resume and motivation letter as the case may, at the email address indicated in the “Careers” section of the Websites (“Application Data”). No Application Data is therefore processed, as such, on the Websites.

3.3 Pharmacovigilance

 

The Belgian Federal Agency for Medicines and Health Products (“FAMHP”) defines the pharmacovigilance as “the sum of techniques for the evaluation of the risk of occurrence of adverse effects with medicines after being marketed”.

 

Healthcare professionals are under the statutory obligation to report (serious) adverse effects in relation to marketed medicines and health products. For more information on such (serious) adverse effects, please go to the “Pharmacovigilance” section of the Website.

Although WILL highly recommend that you first contact your doctor in the event of adverse effects, WILL enables you – in accordance with WILL’s legal obligations and Articles 6, § 1, c) and 9, § 2, (i) of GDPR – to notify any such (serious) adverse effect to WILL

  • by email at pvwillpharma@qplusconsult.com;
  • by phone at  +32(0)2 899 05 68; or
  • by postal mail at Will-Pharma SA – Pharmacovigilance, Rue du Manil 80, 1301 Wavre, Belgium.

The information on your identity (first and last names, (email) address), the medicine or health product that you used and your description of experienced adverse effect(s), as well as any additional information you freely provide in relation therewith (the “Pharmacovigilance Data”) will be exclusively processed by the department that is responsible for the pharmacovigilance.

WILL has put in place the appropriate measures to ensure the security and confidentiality of the Pharmacovigilance Data, taking into account their sensitive nature.

No Pharmacovigilance Data are processed, as such, directly on the Websites.

 

3.4 Sensitive Personal Data

Special categories of Personal Data are often referred to as “sensitive” Personal Data and mean information related to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health or sex life.

Generally, WILL does not collect or process any sensitive Personal Data related to you directly on the Websites. However, as explained in section 3.3, WILL processes Pharmacovigilance Data which contain sensitive Personal Data related to your health, when you notify any adverse effect as the case may be.

Finally, you can freely decide to disclose certain sensitive Personal Data in your resume and/or motivation letter when applying for a position at WILL as mentioned in section 3.2

 

4. Purposes of processing of Personal Data

WILL collects, processes and uses Personal Data related to you solely for the purposes indicated in this Privacy Policy. The purposes for which WILL processes your Personal Data are to provide the Websites and the related services, to manage the contractual relationship with you, to process and answer to your requests, to process your job application as the case may be, and to comply with WILL’s Pharmacovigilance obligations.

In addition, WILL may process your Browsing Data, Request Data and Profile Data for monitoring the use of the Websites, analyzing the habits of the users, designing additions or new functionalities enhancing the Websites and for market research purposes. To the greatest extent possible, WILL shall process aggregate data (which is data that does neither identify you nor can be linked to you, such as statistic data), pseudonymized or anonymized data, rather than Personal Data, when the purposes of such processing can be achieved in the same way.

If you consent to the use of your Personal Data for commercial communications and advertising purposes, WILL will use your data for the purposes for which you have granted consent until you revoke such consent. Subject to your express consent when you communicate your email address and/or mobile phone number, WILL may send you, by email and/or SMS, or by means of “push” or personalized displays on certain social networks with which you have an account, commercial and advertising communications concerning WILL, its products and services. If you wish WILL to stop processing your Personal Data for commercial and advertising communications purposes, you have the right to withdraw your consent in this regard at any time, free of charge and without having to provide any justification. To exercise this right, simply follow the procedure described in section 10 of this Privacy Policy.

WILL may use your Personal Data for new purposes which are as yet unforeseen in this Privacy Policy, either on the basis of an applicable statutory permission or of your consent. In any event, prior to using your Personal Data for other purposes, WILL will inform you about the changes to this Privacy Policy and, in case of consent-based activities, WILL will offer you the possibility to decline participation in these changes.

 

5. Transfer of Personal Data

In the framework of (i) the provision of the Websites and services linked thereto, and (ii) your use thereof, WILL may use the services of suppliers and subcontractors to whom certain Personal Data may be disclosed as part of the services they provide to WILL. In respect thereof, WILL has taken appropriate measures for the protection of your Personal Data, in accordance with the Data Protection Legislation. WILL uses such suppliers and subcontractors for, among others, hosting and maintaining the Websites, storing the databases, managing the Websites underlying platforms and logistics services.  

In connection with the Pharmacovigilance, WILL is under the statutory obligation to disclose the Pharmacovigilance Data to the competent authority, i.e. FAMHP.

Generally, WILL will not transfer your Personal Data to third parties, except the transfers (i) authorized under applicable law; (ii) as mentioned in this section 5 or elsewhere in this Privacy Policy; or (iii) to other entities of the Will-Pharma group, to the extent that it is necessary to achieve the above-mentioned purposes.

You also consent to the transfer of your Personal Data in the event WILL sells or transfers all or a portion of its business or assets to a third party.

Except as specified hereunder, WILL does not transfer sell or market your Personal Data to third parties unless you have given your express consent.

To the extent that any of the above involves the transfer of Personal Data to countries outside of the European Economic Area in countries not considered by the European Commission as ensuring an adequate level of personal data protection, WILL shall ensure that measures are put in place in accordance with the Personal Data Legislation. 

 

6. Personal Data retention period

Your Personal Data, as collected and processed by WILL in accordance with this Privacy Policy, will not be kept for longer than necessary to achieve the purposes specified in section 4 above. Without prejudice to the generality of the foregoing, your Browsing Data and Profile Data are kept for as long as you use the WILL services in connection with which the processing of such Personal Data occurs. WILL will retain your Personal Data for a longer period of time only if WILL has a specific legitimate interest in doing so, for example, if it is necessary to defend WILL’s interests in the framework of legal proceedings; to the extent the data is required to clarify an alleged infringement of third party rights; or to comply with a legal obligation. In this regard, please note that the Pharmacovigilance Data are possibly kept as long as the medicine or health product to which they refer are being marketed. Furthermore, Pharmacovigilance Data are anonymized.

Your Application Data will be kept for a period of two (2) years from WILL’s decision to hire you or not. Without prejudice to the generality of the foregoing, if you are hired, your Application Data will be joined to your employment contract and therefore retained in accordance with the provisions of said employment contract and WILL’s work regulations.

 

7. Security and confidentiality of Personal Data

WILL has put in place the required security measures in order to protect the Personal Data obtained through the use of the Websites and related services against accidental or unauthorized destruction, loss as well as illicit or unauthorized modification, use, access and other processing. WILL takes steps to maintain the confidentiality of Personal Data and protect it from unlawful disclosure. WILL will not make your Personal Data publicly available.

 

8. Cookies and social media plugins

We use cookies and social media plugins at Will pharma that allow our website to work and help us to understand the preferences and browsing behaviour of our visitors.

More information about cookies can be found in our Cookie statement

 

9. Links to third party websites

The Websites may create links to other websites, which are not subject to this Privacy Policy. We recommend that you examine the privacy policy applicable to these other websites. WILL assumes no responsibility whatsoever for the personal data and privacy practices of such websites and encourages you to review each website’s privacy policy before disclosing any Personal Data.

 

10. Your rights

You have the right to access to your Personal Data, as collected and processed by WILL and to request their rectification or suppression (as the case may be) in the event that they would be inaccurate or unnecessary. In order to exercise your rights, you only have to send a written and signed request to WILL at the email address dpo@willpharma.com, together with a copy of the front side of your ID card or other identification document, as well as any document proving that you are the data subject of the Personal Data. If, at any time, you wish that your Personal Data be no longer processed (and not to be contacted anymore) for commercial communications and advertisements, you may oppose to the future processing of your Personal data for such purposes, at any time, free of charge and without having to provide a justification by following the procedure outlined here above in this section 10.

In general, you are entitled to withdraw your consent to any processing based thereon (if any) at any time. This withdrawal of consent does not compromise the legality of the processing based on consent made prior to such withdrawal.

In the event that you consider that the processing of your Personal Data by WILL infringes the Data Protection Legislation, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of the European Union of your usual place of residence, place of work or the place where the infringement occurred. The Belgian supervisory authority is the Data Protection Authority (https://www.dataprotectionauthority.be/). With respect to the Dutch Website, the supervisory authority is the Autoriteit Persoonsgegevens(https://autoriteitpersoonsgegevens.nl/)