Privacy Policy | Swixx BioPharma | Modern Medicines for All

1. You may be a person named in a contract concluded with you or with the organization you represent; in such case, we process your personal data in order to conclude and perform the contract, for example, to pay remuneration, arrange flight tickets, hotel accommodation and registration for an international event, or to record and publish a lecture, or to comply with a legal obligation as further regulated in applicable national and/or international legislation establishing which identification data must be indicated in contracts for them to be treated as concluded, or based on our legitimate interest, namely for the establishment, exercise and defense of legal claims, including the storage of communication or correspondence, or for the performance of due diligence under our legitimate interest in order to ensure ethical, transparent and legally compliant interactions, while protecting both the Company’s and the data subjects’ interests, including reputation, proprietary information and fair treatment. If you are a healthcare specialist who receives a transfer of value from us, we may process and disclose your personal data as part of the reporting of transferred values under a legal obligation as further established in applicable national law or, where such legal obligation does not exist, based on your consent.

Your name, address and contact details (such as email address, telephone number, workplace, professional area, job title and organizational contact details), signature, bank account details (if you are a vendor of the Company), identification data required for contract conclusion and performance and for tax calculation, declaration and payment, your image and/or voice, membership in professional or other organizations, interests in companies or organizations doing business with the government or providing products or services, and other information provided in conflict-of-interest or due diligence forms and in communication/correspondence.

2. Invitations and organization, including registration for events or meetings that we organize or sponsor; in such cases, we process your personal data in order to facilitate your participation in such events or meetings based on your consent and/or for contract performance, as well as to keep records of participants due to medicinal product promotion and fiscal requirements in order to comply with legal obligations as further established in applicable legislation or pursuant to a legitimate interest in ensuring transparency of the hospitality provided during meetings or events and ensuring accountability for the reasonable use of the Company’s financial resources. In cases where we ask participants about nutritional requirements that may reveal health-related information, such personal data are processed based on your consent, which is deemed to be given when you provide information about special nutritional requirements. If we intend to take photos and/or videos during an event or meeting at which you may be recorded, for the purpose of presenting our activities internally and externally or sending memories of the event or meeting to participants, we will request your prior consent, unless applicable legislation allows taking pictures or videos without specific consent. In such cases, we process personal data based on a legitimate interest in presenting and publicizing our Company and its activities.

Your name, address and contact details (such as email address, telephone number, workplace, professional area, job title and organizational contact details), signature and other information related to participation in the event, for example, your photo, dietary requirements and information about hospitality provided during a particular event or meeting.

3. Your request for information about the Company, in order to allow us to communicate with you by electronic means or through face-to-face interactions on topics of your interest. We process such personal data based on your consent.

Your name, address and contact information (such as e-mail address, telephone number, your place of work, professional area, and organization contact information).

4. Information provided by a healthcare service provider about the patient and the treating physician in connection with an application for early access to a particular product is processed under the legitimate interest of the marketing authorization holder/manufacturer, namely to make a decision on the feasibility of granting such early access to the product. Please note that we process such information as a data processor. For more information on how your personal data are processed by the data controller, please visit the website of the marketing authorization holder/manufacturer of the product for which early access is requested.

Full name, contact details (phone number, email address), workplace, specialization and title of the treating physician and/or representative of the healthcare service provider, as well as anonymized or pseudonymized information about the patient who requires a particular medicinal product (including, but not limited to, age, gender, disease and required volume of the medicinal product).

5. Information related to you in your job application, such as your CV, references, education and other professional certificates. This personal data processing is based on your consent given when applying for a vacant position or on our legitimate interest in selecting the most competent person for a vacant position and in defending Swixx against claims related to the recruitment process.

Your name, address and contact details (such as email address, telephone number, workplace, professional area, job title and organizational contact details), education and experience, references and other information collected during the recruitment process, including the position for which you applied.

6. Personal data required for providing a response to a query received from a subject involved in communication or correspondence, or for the preparation of an inquiry or other type of document for a subject in connection with the exercise of the Company’s legitimate interests in the establishment, exercise and defense of legal claims, including the need to store communication or correspondence.

Full name, address and contact details (email address and phone number), as well as other identification details, such as date of birth or unique personal identification number.

7. Personal data related to the development of disease awareness, patient stories or similar projects, processed based on your consent and/or for the conclusion and performance of a contract, for example, to prepare a contract, produce a video and publish it, etc.

Full name, address, email address, phone number, status of the person (patient, caregiver, relative or healthcare professional), health-related information (type of disease, symptoms and challenges, etc.), image, voice and photograph.

8. Information required for the purposes of sanctions compliance, registration and disclosure of the ultimate beneficial owners of the Company, and for the performance of “Know Your Client” procedures, in order to comply with legal obligations established in national and/or international laws and to assess whether a vendor, including its beneficial owners, directors, managers and other key personnel, has a good reputation under our legitimate interest in ensuring that business relationships with legal entities, their beneficial owners, directors, managers or other key individuals do not pose legal, financial or reputational risks, thereby protecting our transparency, compliance and reliability in our operations. Some information may also be processed based on your consent where applicable legislation provides that certain data may be processed only with the consent of the data subject.

Full name, date of birth, citizenship, country of residence and address, and relevant evidence such as invoices or similar documents to demonstrate the connection, a copy of a personal identification document, percentage of ownership and/or number of owned shares, type of shares, date and number of shares acquired and/or transferred, and other data provided by you when completing questionnaires or responding to our request to provide data required pursuant to legal regulations or “Know Your Client” requirements.

9. Personal information required for the conclusion and performance of an employment contract, for example, the preparation of an employment contract, salary calculation and payment, provision of benefits or assets, and the performance of the employer’s legal obligations related to employment, occupational safety, occupational health or benefits or assets, as further specified in applicable legislation governing employment, occupational health and safety and fiscal obligations, as well as for conflict-of-interest purposes constituting a legitimate interest of the Company in ensuring employees’ independence, integrity and impartiality when performing activities within the scope of their functions, protecting the Company’s proprietary information from use for purposes other than the Company’s interests, and ensuring compliance with fair competition rules in the relevant markets, as part of training management constituting a legitimate interest in ensuring that required training is provided on time and to the appropriate personnel. The Company may process your personal data for the purpose of presenting its employees internally and externally and promoting the Company’s activities based on your consent.

Full name, address and contact details (phone number and email address), job title and workplace, date of birth, unique personal identification number, social security number, bank account details, trade union membership, health-related information (e.g. pregnancy, absence from work due to sick leave, the healthcare provider that issued the occupational health certificate and the information indicated in such certificate), information about your interests in other legal entities provided in a conflict-of-interest form, your photograph or recorded image, information on what training you have completed and when, benefits or assets provided to you, and other personal data related to your employment.

10. Personal data related to the carrying out of surveys pursuant to our legitimate interest in making improvements to work and/or the organization of events, activities and operations in order to better reflect expectations and enhance individual experience in any type of interaction with the Company, unless such personal data are processed based on the data subject’s consent, in which case such data are processed only with your consent.

Full name, country of residence, contact details (phone number and email address), status of the person involved in the survey (e.g. employee, event participant, etc.), expressed feedback on survey questions (e.g. years of working with the Company, what the data subject likes and dislikes in relation to the operation or circumstances in scope, recommendations for further improvement and similar). Please note that the Company usually conducts anonymous surveys and may be aware of the audience involved in a survey, but not of individual responses to survey questions.