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.
Registered offices Belgium:
Rue du Manil 80, B-1301 Wavre
Fax: +32 (0)10 24 33 77
Rue du Merschgrund 54 – L8373 Hobscheid (Habscht)
Phone: +352 (0)45 09 86
Fax: +352 (0)45 09 87
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
Categories of Personal Data processed
- 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.
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 www.willpharma.com.
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 email@example.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
Purposes of processing of Personal Data
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.
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.
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.
Personal Data retention period
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.
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.
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Links to third party websites
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 firstname.lastname@example.org, 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/)