This is an important notice regarding your privacy and the way in which Aspire Pharma (referred to as “We” and “Us” in this policy) collects and makes use of your personal data. By visiting our website and using our services, or by calling or emailing us, you agree to this privacy policy. This privacy policy also applies to virtual, face to face meetings or appointments with our representatives.

We take our privacy responsibilities seriously and are committed to protecting and respecting our customers’ privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of applicable privacy legislation, the Data Controller is Aspire Pharma Limited of 4, Rotherbrook Court, Bedford Rd, Petersfield GU32 3QG. Our company registration number is 06828501.

Questions regarding this policy should be directed to [email protected]

1. What information do we collect from or receive about you?

We will collect and process the following data about you:

• Information you give us when you call us on the telephone number listed on our website, email any of the contact emails listed on our website, speak to or contact any of our employees, including in virtual, face to face meetings or appointments or visits to our offices.
• You may give us your contact information, such as your name, email address, telephone number, job title, work or personal address, depending on the nature of your query, report, or interaction and details of your query, report or interaction;
• You may also give us special categories of information, such as health related information, if your query or report is of a medical information, drug safety or quality complaint nature.

Information we collect about you:

• We may collect information about you from your business/institution’s website or other publicly available information about your role and place of work;
• By using our website, you are indicating that you consent to our Cookies Policy.

2. How do we use the information?

We use information held about you in the following ways:

Information you give to us, and we collect about you.

We will use this information:

• • to deal with your query or report when you call, email or send a secure enquiry;
  • as explained or agreed with you at the time of our interaction;
  • to contact you if we wish to use your information for a purpose not set out in this policy, such as to invite you to a meeting or to arrange a visit by one of our representatives.

Monitoring usage of our website.

We intend to continue to improve the content and function of our website. For this reason, we may monitor customer traffic patterns and usage of our website (see our Cookies policy).

3. Disclosure of your information

We will share your information with the following categories of selected third parties:

• the third party service provider which hosts our website;
• the third party service provider which provides us with our pharmacovigilance/drug safety service;
• third party Marketing Authorisation Holders (licence holders) or Legal Manufacturers if your report or query is about a product which we sell on their behalf;
• third party service providers who assist us with arranging meetings or appointments;
• other third parties to whom we are under a duty to disclose or share your personal data in order to comply with any legal obligation or public task; or to protect the rights, property, or safety of Aspire Pharma, our customers, or others.

4. Basis for processing your personal data

Generally, we rely on either a legal right to collect/process your information or our legitimate interests for collecting/processing your information, to correctly deal with your query or report or to interact with you in a business function. If your query or report is of a special category (for example for drug safety reporting) we rely on our legal right and public task, to ensure that high standards of quality
and safety of healthcare and of medicinal products or medical devices are met.

Where we disclose your personal data to third parties

We rely on the same lawful basis to disclose your data and we ensure that our third-party data processors also comply with data protection requirements.

5. Where we store your personal data

Electronic versions of the information you provide to us, or we collect about you, is stored on our company or email servers or secure cloud-based storage. We have taken appropriate measures to ensure our servers and cloud-based storage are safe and secure including restricting physical access, password protection and installing antivirus and firewall software.

Paper copies of your information are stored in locked cabinets in an access-controlled office.

6. How long we will store your personal data for

We store different personal data for different times depending on what the data is and what it is being used for.

If your query is of a medical information nature, drug safety report or quality complaint, we may need to store it indefinitely (for as long as we have a licence for the product you are taking, plus another 10 years).

7. Use of CCTV

CCTV is installed at the Aspire Pharma Limited premises namely Rotherbrook Court, 4, Bedford Rd, Petersfield, GU32 3QG and is controlled by Beady Eye Security Ltd. If you visit our offices your images may appear on our NVR (Network Video Recorder). These Images will be stored for a maximum of 28 days. Link to Beady Eye Security’s GDPR privacy policy can be found here https://www.beadyeyecctv.co.uk/privacy-policy/

8. Your rights

You have the following rights in connection with your personal information held by us:

• you may request information on what personal data we hold and access to it;
• you may request we rectify any data we hold about you (i.e. if the data is incorrect), erase that data or restrict the types of processing we carry out in respect of that data;
• you may request we provide you with the personal data we hold about you in order that you can use it for your own purposes across other services.

Please contact [email protected] to request any information on the personal data which we hold about you. If you believe that the information we hold about you is not accurate, complete or up-to-date, please contact us in writing.

9. Changes to our privacy policy

Any changes we make to our privacy policy in the future will be uploaded to our company website. We may change, modify, add or remove portions of this policy at any time, and any changes will become effective immediately, and will apply to personal data collected on or after such date. If you are a regular user of our website you are encouraged to review this policy from time to time.

10. When and how to contact us

If your personal details change or if you have any queries about how we use your information or any feedback about our privacy practices, please contact us at [email protected]

If you believe that we have not complied with this policy or that we have acted otherwise than in accordance with Data Protection Law, you can also complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk/). We would be grateful if you could contact us directly, to see if we can resolve it, first.