Notification Regarding the Processing of Personal Data
I. Who is Zenyth Pharmaceuticals?
Zenyth Pharmaceuticals LLC (hereinafter referred to as “the Company”), located in Neamț County, Alexandru Cel Bun commune, Bistrița locality, Petru Rareș Street no. 50A, registered at the Trade Register under no. 21917821, VAT no. J27/805/2007, processes personal data in accordance with the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 (the Regulation) and other applicable legal provisions concerning the processing of personal data. The Company acts as a Data Controller, under the number 17057. This information note describes why and how we process personal data and provides information about your rights. This notice applies to all Zenyth sites, namely: www.zenyth.ro, www.beautyhelp.com, www.artrohelp.ro, www.colonhelp.ro, www.biogreens.ro, www.ziaruldesanatate.ro, www.bettermedicine.ro.
You can contact us in the following ways: Address: Zenyth Pharmaceuticals, Petru Rareș Street no. 50A, Alexandru cel Bun commune, Bistrița locality, Neamț County, phone: 0233.222.203.
Website: https://zenyth.ro/contact/
Email: office@zenyth.ro.
- Data or categories of personal data processed by the company
Generally, we collect personal data directly from you (by placing online or telephone orders for Zenyth products, by filling out the order form, by subscribing to the newsletter). However, there are situations where we may also receive personal data from other sources, such as personal data or access to it from our clients and partners, legal entities, public institutions and authorities, third parties, or public sources of information, etc. Our policy is to collect only the personal data necessary for agreed purposes, and we ask our clients to communicate personal data only where it is strictly necessary for these purposes. Due to the diversity of products and services we offer, we may process multiple categories of personal data, depending on the type of product/service/activity/purpose of the processing. The main data/categories of data processed by the Company can be, depending on the purposes associated with the processing, one or more of the following: General such as, but not limited to: – identity data such as, but not limited to, name, surname, series and number of identity document/civil status document, etc. – contact data such as, but not limited to, email address, home address, phone number, etc. – data related to profession, the capacity of representing a legal entity, workplace, etc. – photo/video images from spaces used by the Company or related to events organized by it. – data obtained from your physical or online access to the Company’s platforms (data from the access system in the Company’s spaces, the online identifier of individuals accessing the Company’s Site processed for the purposes mentioned in the Cookie Policy (for more information visit https://zenyth.ro/politica-utilizare-cookies/), potential data received through social media platforms (for example, Facebook, Instagram).
- Purposes for which personal data are processed
Our company processes personal data for the purposes stated in this information note, and each purpose may involve one or more data processing operations. The Company processes personal data for multiple purposes, and the methods of collection, legal basis for processing, use, disclosure, retention periods, etc. may differ depending on each purpose. We may use personal data for one or more of the purposes described in this notice. If the Company subsequently processes personal data for a different purpose than those you have already been informed about and which is not compatible with the purposes for which the data was originally collected/ made known to you, the Company will provide information regarding that secondary purpose and any relevant additional information. We primarily use personal data for the following purposes: – Conducting the Company’s business object, as well as related activities. – Managing business relationships with customers, suppliers, distributors of pharmaceutical products, medical and/or pharmaceutical professionals, etc., improving the Company’s activities and services in relation to our customers, suppliers, and partners, correspondence, offers, negotiations, contract management. We process personal data for the purpose of fulfilling contractual obligations and commitments assumed towards you. – Managing risks related to our activity, in which we take security measures to protect personal data, which involve detecting, investigating, and resolving security threats. – In accordance with applicable law, we use the contact details of our clients and partners to provide directly or indirectly information that we believe to be of interest to them. We may process personal data for organizing dedicated events, specialized congresses, marketing activities, such as marketing promotions or research, without limiting ourselves to these. – When visiting our websites or our social media pages, we may process some information about the online identifier of the visitor for the purposes mentioned in the Cookie Policy (for more information visit https://zenyth.ro/politica-utilizare-cookies/). – Compliance with legal and/or regulatory requirements, such as tax requirements or those required by special legal acts regulating our business object, or, as applicable, archiving. – Economic-financial-administrative management. – Establishing, exercising, or defending a legal right in court. – Internal statistics.
- Legal bases and conditions of legality on which data processing is based
The legal bases for processing take into account the provisions of EU Regulation 2016/679 and the legal acts regarding the processing of personal data adopted in Romania, but also other legal acts applicable at the national and European level. Processing is necessary for the legitimate interests pursued by the Company or a third party, namely: – for the administration of our activity, – for managing risks related to our activity, – for managing our relationships with potential clients and clients or business partners, including but not limited to sending communications containing information and offers regarding our services and/or products, as well as those of our partners, within the limits of the law, organizing specialist conferences and product presentations. – managing complaints/claims related to our products, in order to be able to resolve any reported issues, respectively to be able to improve our products and/or services, establishing, exercising, or defending a legal right in court. – processing may be based on your consent, in cases expressly provided by the Regulation in this respect.
- How long do we keep personal data?
We keep personal data processed only for the period of time provided by legal provisions or as long as necessary for the purpose for which they were collected, such as: – During the duration of the contract for personal data necessary for its execution, including personal data with which the Company may come into contact in the conduct of the legal relationship; – Until the expiration of the limitation period, concerning cases where the Company has a legitimate interest in keeping certain personal data in connection with a potential litigation that may arise between the parties; – During the management of the relationship with potential clients/clients/recipients of our products/partners of the Company and their representatives, respectively until the exercise of the right to opt-out, for sending communications containing information and offers regarding our services and/or products, commercial communications, invitations to events such as symposia, conferences, presentations, etc; – Until the withdrawal of consent for data processing based exclusively on consent;
In any other hypotheses or in the absence of specific legal, regulatory, or contractual requirements, our reference period for keeping personal data is 3 years from the date of termination of relations/last contact between the Company and the person concerned. Any data may be kept by the Company, exceptionally from the foregoing provisions if the case, until the expiration of the limitation period, concerning situations where the Company would have a legitimate interest in keeping certain personal data in connection with potential litigation that may arise between the parties, for example, in the context of the possible legal liability of Zenyth or the person concerned by the processing. In any situation, except in situations provided by applicable legislation, we delete your data at the time you request it. Exceptional situations applicable will be communicated to the applicant through the response forwarded by our company, in connection with the request for deletion of data.
- Recipients or categories of recipients of personal data:
The Company may transmit, grant access to, and/or disclose personal data mainly to the following categories of entities: – business partners (distributors of supplements and pharmaceutical products, professionals in the medical and/or pharmaceutical field, etc.) – service providers and/or authorized persons who process personal data on behalf of the Company, in accordance with the instructions received from us, only if they comply with this information note, data protection laws, and any other appropriate confidentiality and security measures (such as specialized courier companies, event organization, marketing service providers, access and video monitoring, IT service providers who may have access to personal data, etc.). Transfers and disclosure will not be made to entities outside Romania or the European Union. If the Company transmits your personal data to a third country or to an international organization, we will ensure that they are adequately protected, namely that we transmit the data to a country that ensures an adequate level of protection according to the assessment by the European Commission or, if it is considered that the respective country does not have laws equivalent to EU data protection standards, we will ask the third party to conclude a contract or agreement that reflects compliance with standards or to provide other adequate guarantees in this respect.
- Consequences of refusal to provide personal data
If personal data are collected directly from you, we inform you that, as a rule, you are not required to provide your personal data to the Company, except in cases where their provision constitutes a legal or contractual obligation or a necessary requirement for the conclusion of a contract. Thus, to the extent that you enter into a legal relationship with the Company or benefit in another context from our services/products, the provision of personal data constitutes a necessity from the perspective of legal requirements and/or the legal relationship with us, as this information is necessary to fulfill the obligations assumed by the Company in relation to you or to provide products and/or services. By reading this information, you have become aware of the information provided by Zenyth Pharmaceuticals in light of Regulation 679/2016 and have been informed about the rights conferred by the Regulation and Romanian law regarding the protection of individuals concerning the processing of personal data and the free movement of such data.
II. Your rights and how to exercise them
Our company is responsible for facilitating the exercise of any of your rights mentioned below. To exercise these rights, as well as for any additional questions regarding this notice or in connection with the use by the Company of personal data, please contact us by choosing any of the communication methods described in section I of this notice.
For the protection of your data, to prevent the abuse of malicious individuals who might seek access to your data, our company may ask you to go through certain identification steps beforehand to ensure that you are the person exercising the rights mentioned below through a request. If we receive a request from you regarding the exercise of any of the above rights, we may ask for additional information to verify your identity before acting based on the request formulated. If the data subject submits a request in electronic format to exercise their rights, the information will be provided by our company also in electronic format where possible, except where the data subject requests another format. In the event that, as a result of the application of legal provisions, our company cannot comply, in whole or in part, with a request from the data subject, then the applicable exceptional situations will be communicated to the applicant through the response forwarded by our company concerning the request in question.
Right of access
You have the right of access, namely to obtain from the Company a confirmation as to whether or not personal data concerning you are being processed. At your request, the Company provides a copy of the personal data that are the subject of processing.
Right to rectification of data
You have the right to obtain from the Company, without undue delay, the rectification of inaccurate personal data concerning you. Considering the purposes for which the data were processed, you have the right to obtain the completion of incomplete personal data, including by providing a supplementary statement.
Right to erasure of data
You have the right to obtain from the Company the erasure of personal data concerning you, without undue delay, except in certain hypotheses provided by the Regulation, if one of the following reasons applies:
a) the personal data are no longer necessary for the purposes for which they were collected or otherwise processed; b) you withdraw your consent on which the processing is based to the extent that the processing is based exclusively on consent and there is no other legal basis for processing; c) you object to the processing carried out for a public interest or for the legitimate interests pursued by the Company or a third party, and there are no legitimate reasons that prevail over your interests/rights and fundamental freedoms concerning the processing, or you object to the processing for direct marketing purposes; d) the personal data have been unlawfully processed; e) the personal data must be erased to comply with a legal obligation incumbent on the Company under the law of the Union or of the law under which it is subject; f) other situations provided by the Regulation to the extent that they are applicable. Right to restriction of processing
You have the right to obtain the restriction of processing in the cases expressly provided by the Regulation (for example, in the case where you contest the accuracy of the data, the restriction of processing will be granted for the period necessary to verify the contested data).
Right to data portability
You have the right to receive your personal data which you have provided to the Company, in a structured, commonly used, and machine-readable format, and to transmit them to another operator, without hindrance from the Company, under the conditions expressly provided by the Regulation.
In the event of exercising the right to data portability, the data may be transmitted directly by the Company to another operator indicated by you explicitly, where this is technically feasible.
Right to object
At any time, you have the right to object to the processing of your personal data. In this case, the Company will no longer process your personal data, except where it demonstrates that there are legitimate and compelling reasons that justify the processing and that prevail over your interests, rights, and freedoms or if the purpose is the establishment, exercise, or defense of a legal right in court.
When processing is aimed at direct marketing, you have the right to object at any time to the processing for this purpose of personal data concerning you, including the creation of profiles to the extent that it is related to the respective direct marketing.
Right to withdraw consent
If processing is based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. The hypothesis of withdrawal of consent is not applicable in cases where the basis for processing is not consent.
III. Right to file a complaint or a claim
If you wish to complain about aspects concerning the use of your personal data, please send your complaint through any of the contact methods provided in section I of this notice. Any complaint will be analyzed within a reasonable time, and the complainant will receive a response from the Company within the legal deadlines. You also have the right to file a complaint with the National Authority for the Supervision of Personal Data Processing (“ANSPDCP”).