Privacy Policy
Thank you for visiting the website of "GENEPHARM S.A. PHARMACEUTICAL COMPANY" with the address at 18th km. Marathonos Avenue, 15351, Pallini, G.E.MI. number 000276001000, contact telephone number: +30 210 603 9336, email address:
If you have any questions, please do not hesitate to contact us using the following contact details:
- To the following address: by post to the Data Protection Officer: 18th km Marathonos Avenue, 153 51, Pallini, Attica.
- By e-mail at
By providing Personal Data to the Company or using its website, you consent to the collection and processing of such data by our Company for the purposes and according to the terms described in this Policy. The provisions for the protection of Personal Data contained herein supplement the Terms of Use of our Company's website (Terms of Use).
1. Definitions
Personal data: any information relating to an identified or identifiable natural person. An identifiable natural person is one whose identity can be verified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
Special categories of personal data: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade-union membership, as well as the processing of genetic data, biometric data for the purpose of positive identification of a person, data concerning health or data concerning a natural person's sex life or sexual orientation.
Processing: any operation or set of operations which is performed, whether or not by automated means, on personal data or on sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Data Protection Officer (DPO) : the natural or legal person who has assumed the duties of the Company's advisor to ensure the Company/Organisation's compliance with personal data protection issues.
2. Personal Data to be processed.
The Personal Data that may be subject to Processing by the Company mainly concern ordinary Personal Data that you provide when using the functions of the website, such as browsing data, requests to use services, and data collected by cookies, in accordance with the terms of use described below.
By simply visiting the website, the Processing is limited to the browsing data, i.e. those necessary for the operation of the website and web protocols. In addition, the Company may collect data that you provide directly, such as when you subscribe to newsletters, send emails or provide your details at any point on the website.
In some cases, you may provide Special Categories of Personal Data, such as health data, in particular as part of the pharmacovigilance system, which are also processed to comply with the Company's legal obligations.
3. What Data we collect from you.
During your visit and navigation on our website, we collect your Personal Data that you choose to provide to us during your browsing. In particular, by filling out the contact form on our website, or contacting through the contact channels of the website, we may collect the following Personal Data:
- Basic personal data (e.g. Name/Name),
- Contact Data (e.g. email, phone number),
- Work data (e.g. the company you work),
- Message content data (e.g. CV data if you send us your CV via the form in the website),
- Special category data (e.g. health data in case you contact us about pharmacovigilance).
Also, when you visit the website, the internet service provider may automatically collect information such as your IP address, the operating system you use to log in, the date, your browser. This information is collected to ensure the technical operation of the website and to ensure optimal adaptation of the information to your device. This data is recorded as statistical or action files (log files). Usually, browsing data is deleted after being processed in an anonymous form, but it may be stored and used to track and identify individuals who commit computer offences at the expense of or through the website.
Also, any of your data collected by the technically necessary cookies, which are absolutely necessary for the operation of our website and are always enabled, without the possibility of deactivating them, may also be processed. Detailed information on cookies can be found in the Cookies Policy, here.
4. Personal Data of Children.
In general, we do not process Personal Data of children, as the services of our website are not addressed to them. By using our website, you confirm that you are over sixteen (16) years old. If you are under the age of sixteen (16), you have an obligation to refrain from any use of the Website and not to provide your Personal Data without the consent of the person exercising parental authority over you. If you fail to comply with the above obligations, you must immediately notify the Company, which is not responsible for any breach of these obligations on your part as, despite its reasonable efforts, it is unable to verify your age or confirm the consent of your parent or guardian.
5. Purposes of Processing of your Personal Data.
We process your Personal Data exclusively for the purposes of the services provided by our Company, as well as for the generally smooth operation of our website, and in particular:
a) to ensure the security of information and the proper functioning of the website, and/or
b) for our communication with you in the information you provide through the contact form or other communication channels.
6. Legal basis for the Processing of your Personal Data by the Company.
In order to ensure information security and the proper functioning of the website (purpose "a"), the legal basis of the processing is the pursuit of the legitimate interests of our Company, and in particular, it seeks to ensure the proper functioning of the website through the use of technically necessary cookies, as well as the protection of data and intellectual property of both the Company and our website visitors.
For contacting you about issues for which you have used the contact form or the contact channels (purpose "b"), the legal basis is distinguished according to the category of issue you wish to contact us about. The following illustrates the legitimate basis of Processing by subject category:
i. For matters relating to information about our products in Greece and international products, the legal basis of Processing is the pursuit of the legitimate interests of our Company and in particular the promotion of the Company's products and the provision of relevant information about them.
ii. For employment/career opportunities (e.g. sending CV Data via the contact form), the Processing of your Personal Data is necessary in view of the possible performance of the contract between us. Where applicable, you have consented to the Processing of your Personal data for one or more specific purposes, such as when you voluntarily send your CV to our Company's published addresses.
iii. For pharmacovigilance issues, the Processing of your Personal Data is necessary in the context of our compliance with our legal obligations, and in case your message contains Special Categories Data (e.g. health data related to pharmacovigilance such as diseases, adverse symptoms, etc. ), the Processing of such data is necessary for reasons of public interest in the field of public health, such as protection against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare and medicines or medical devices under the existing legal framework. More information on the Processing we carry out in the context of pharmacovigilance can be found here.
iv. For any other matter that you wish to contact us about that does not fall into the above categories, the legal basis of the processing is the pursuit of our Company's legitimate interests.
7. Recipients of your Personal Data
The recipients of your Personal Data are generally the competent personnel of the Company in each case, who have received the appropriate information for the secure processing of your Personal Data.
In addition, recipients of your Personal Data is the company that manages and hosts our website, as well as the information systems service provider.
Finally, recipients of your Personal Data may in certain cases, such as in the case of communication management in the context of pharmacovigilance, be competent audit or regulatory authorities, such as the EOF. More information on pharmacovigilance Processing can be found here.
Where the recipients are data processors, they have agreed and contractually bound themselves to the Company:
- to process your Personal Data solely in accordance with our instructions and guidance,
- to maintain confidentiality,
- not to send Personal Data to third parties without the Company's permission,
- to take appropriate security measures,
- to comply with the legal framework for the protection of Personal Data and in particular the European Regulation GDPR.
8. Sending Personal Data outside the European Union/European Economic Area.
Your Personal Data is transferred outside the European Union/European Economic Area, namely to the USA due to the use of an information system provider (Microsoft 365). This transfer is under the legal guarantee of the adequacy decision (EU-US Data Privacy Framework).
9. Retention of Personal Data
The Company will retain your Personal Data for as long as there is any transactional or other relationship between you and the Company. The determination of the data retention period is based on various criteria, including :
- The nature of the data
- The purpose of the Processing
- The legal and regulatory requirements as applicable in the environment in which the Company operates
- The value of the data to the Company.
- Obligations arising from data retention, whether legal or contractual.
The retention period also depends on: i) legal requirements (e.g. tax provisions, data retention obligations for pharmacovigilance), ii) the nature of your relationship with the Company.
If the necessary retention period for your Personal Data has expired, it will be deleted from the Company's databases, unless further retention is required to satisfy our legal claims or is required by applicable law.
10. Security of your Personal Data
The Company implements various security measures and technologies to protect your Personal Data from unauthorized access, use, disclosure, alteration or destruction, in accordance with the laws on the protection of Personal Data. These include technical and organizational measures such as:
- Anonymization and pseudonymization of data.
- Electronic Security Certificate (SSL - Secure Socket Layer), to ensure secure data exchange between the website and your browser.
-Encryption to protect the information.
- Firewalls to prevent unauthorized access.
- Application of data protection principles by design and by default (privacy by design and by default).
- Strict access policies.
- Confidentiality commitments for employees.
- Continuous training of staff.
- Periodic security audits.
Although the necessary measures are taken, no data transmission or storage system can guarantee 100% security.
When your Personal Data is shared or transferred to third parties, the Company ensures that the data is kept confidential and that appropriate security measures are in place to protect it.
These measures are reviewed and modified when necessary.
11. Your rights
You have the right to access your Personal Data.
This means that you have the right to be informed by us if we process your Data. If we process your Personal Data, you can request to be informed about the purpose of the Processing, the type of your data we hold, who we give it to, how long we store it, whether automated decision-making takes place, and your other rights, such as rectification, data erasure, restriction of processing and filing a complaint with the Data Protection Authority.
You have the right to correct inaccurate Personal Data.
If you find that there is an error in your Personal Data, you may submit a request to us to correct it (e.g., correcting your name or updating a change of telephone number).
You have the right to erasure/right to be forgotten.
You can ask us to delete your Personal Data if it is no longer necessary for the Processing purposes listed above.
You have the right to portability of your Personal Data.
You may ask us to receive in a readable form the Personal Data you have provided or ask us to transfer it to another controller where the Processing is necessary for the performance of a contract between us.
You have the right to restrict Processing.
You can ask us to restrict the Processing of your Personal Data for as long as your objections to the Processing are pending or if part of the Processing is no longer necessary to fulfil the purposes for which your data was collected.
You have the right to object to the Processing of your Personal Data.
You may object to the Processing of your Personal Data where it is carried out in the pursuit of our legitimate interests, and we will stop the Processing of your Data unless there are other compelling and legitimate reasons that override your right.
12. Exercise your rights.
In order to exercise your rights, you can send a request to the Company's Data Protection Officer (DPO) at the email address
We will respond to your requests free of charge and without delay, and in any case within one (1) month of receiving your request. However, if your request is complex or there are a large number of requests, we will let you know within the month if we need to obtain an extension of another (2) two months within which we will respond to you.
13. Right to complain
In the event that you believe that: a) your request has not been adequately and lawfully fulfilled; or b) your right to the protection of your Personal Data has been infringed by any Processing carried out by us, you have the right to lodge a complaint with the Data Protection Authority, https://www.dpa.gr/.
14. Links to third party websites
The Company's website may contain links to other third party websites. If you follow these links, you will leave our website and therefore the scope of this Policy. The Company is in no way responsible for the personal data protection practices or policies of third party websites and cannot guarantee the security of your browsing on them. In this regard, we encourage you to read the privacy statements of each and all websites that collect personally identifiable information. This Policy applies only to information collected by our website.
15. Changes and updates to this Privacy Policy
The Company reserves the right to modify and/or update this Privacy Policy at any time. Please check our Company's published Privacy Policy regularly. In the event of any updates and/or material changes to this Privacy Policy, a posting will be made on the Company's website with a corresponding change to the "update date" of this Privacy Policy.
16. Automated decision-making/including profiling when processing your Personal Data
We do not make decisions, nor do we engage in profiling, based on automated Processing of your Data.
Last Revision : 18.10.2024
