Privacy Policy

PRIVACY POLICY
(Date of last revision: 1st March 2024)

Contents
2. What information do we collect and why?
3. GDPR legal grounds for processing data 
4. GDPR Legitimate Interest Assessment (LIA)
5. How do we collect information?
6. Who do we share this information with?
7. Data minimisation
8. Data retention and accuracy
9. Processing data for marketing purposes
10. Data security
11. Data subject rights
12. Complaints
13. Updating the privacy policy
14. Our contact details


1. Introduction
Pharmabase Marketing Ltd is Europe’s leading source of information about pharmaceutical companies, products and people.  

Since 2010, Pharmabase Marketing has collected information about pharmaceutical businesses and their key executives in order to help our clients target their marketing as precisely as possible. In turn, this helps to ensure that communications are more relevant to the recipient and poorly-targeted, irrelevant messaging is minimised.

Pharmabase Marketing’s proprietary pharmaceutical database is called Pharmabase™ and it contains more than 10,000 business records of corporate companies, products and corporate employees.  

Our clients are medical societies, professional/industry associations, companies, agencies and specialist consultancies that operate in, or wish to develop more business from, pharmaceutical, medical device and associated industries. As a result, the communications that we are involved in are wholly and exclusively Business-to-Business (B2B) rather than Business-to-Consumer (B2C).

Although the information we collect is always in the context of a corporate employee’s job role and responsibilities, some of the information may be classified as "personal data" under UK law as it is information relating to an individual.  

This privacy notice provides the information we are required to give in relation to the processing of personal data under EU law and explains how we use the information that we collect about you lawfully and in accordance with the General Data Protection Regulation (GDPR) which came into force on 25th May 2018.

Pharmabase Marketing is registered with the Information Commissioner's Office (ICO).


2. What information do we collect and why?
Pharmabase Marketing processes data so that we can manage precisely-targeted marketing campaigns on behalf of our clients. We also sell professional business contact information to selected companies for their own direct marketing and data management purposes.

We collect information on pharmaceutical businesses, pharmaceutical products and pharmaceutical business professionals; this data is compiled and held in our Pharmabase™ database.  

The information we gather about companies is limited to their office address(es), switchboard telephone number(s), company website address(es) and product/pipeline portfolio. This is compiled from publicly-available sources and desk/telephone research and it is essentially corporate information. 

The information we gather about products comprises the brand name of the drug, its generic ingredients, its licensed indications/therapy areas and its manufacturer (i.e. the company/license holder). This is also compiled from publicly-available sources and desk research and it is essentially product information. 

The information we gather about people relates solely and exclusively to corporate employees within pharmaceutical companies and comprises their name, (title, first name and last name) their job title, their company, their office address and the switchboard telephone number for that company. For some, we also record the company they previously worked for where it is known; their company email address where known; and their specific product/therapy area responsibilities where they have them. This information is also compiled from publicly-available sources and desk/telephone research.

Aside from the Pharmabase™ data outlined above, Pharmabase Marketing also collects contact details of actual or potential customers for our own business and marketing purposes.

In all cases, the data we process is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.  

Pharmabase Marketing does not seek to collect, any information in relation to an individual’s age, marital status, home address, mobile telephone number, home email address, race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, genetic or biometric data.


3. GDPR legal grounds for processing data 
Under GDPR, data controllers such as Pharmabase Marketing must have a lawful basis for processing personal data.

The lawful basis for Pharmabase Marketing to process personal data is that of our legitimate interests: the processing is necessary for our business to operate; there are mutual benefits for both the data controller and the data subject; and, given the nature of the information we process, there is a limited privacy impact on the individual.

Another lawful basis within GDPR is ‘Contractual’. In dealing with clients who purchase our services, it is likely that the lawful grounds for Pharmabase Marketing to process personal data will be both contractual and based upon our legitimate interests.


4. GDPR Legitimate Interest Assessment (LIA)
An essential part of the concept of legitimate interests is the balance between the interests of the controller and the rights and freedoms of the individual.

In relying on legitimate interests for processing personal data, Pharmabase Marketing has conducted a thorough Legitimate Interests Assessment (or LIA). This three-stage assessment identifies our legitimate interests; considers the necessity of processing personal data in order for our business to operate; and considers and balances any potential impact on the data subject (both positive and negative), and the data subject’s rights under data protection laws. 

For more information on your rights, please see section 11, below.


5. How do we collect information?
Our data is compiled from a wide range of sources including corporate websites; governmental and administrative public records; trade associations; industry directories; national, regional, local and trade press articles; conference speaker platforms; congress exhibitor lists; event delegate/attendee lists; clinical papers, posters and abstracts; social media platforms; desk/telephone/internet research; and our own customers.

All data is compiled exclusively by Pharmabase Marketing Ltd; we do not buy in data from third-party data vendors nor do we sell data to third-party data resellers.


6. Who do we share this information with?
Pharmabase Marketing processes data so that we can manage precisely-targeted mailing campaigns (postal and/or email) on behalf of our customers. In most instances, we conduct the mailings ourselves and share only aggregated, anonymised ‘top-line’ information about the data subjects with our customers.

Data subjects may unsubscribe from our emails at any time by clicking the ‘unsubscribe’ link at the foot of the email. In so doing, Pharmabase Marketing undertakes no longer to send emails on behalf of any of our clients and that this will be actioned within a maximum period of 7 days from the receipt of the request.

Where it is necessary to support Pharmabase Marketing’s business operations, we share data with certain service providers such as printers, mailing/fulfilment houses and email software/distribution companies. We contractually require these recipients to be GDPR compliant; only to use personal data for the intended purpose of the disclosure; and to destroy or return it when it is no longer needed.

We also sell professional business contact information to carefully-selected companies that operate in, or wish to develop more business from, pharmaceutical, medical device and associated industries. We contractually require these recipients to be GDPR compliant; to undertake that they will not pass it on to any other company or individual; and to have sufficient measures in place with regard to data security.

We will share data as required or appropriate in order to protect our business operations or legal rights, or in connection with a sale or merger involving Pharmabase Marketing assets or businesses. (In the event that Pharmabase Marketing Ltd is purchased or sells parts or all of the business, the information collected will be considered an asset that can be transferred).

We will share data as required or appropriate to a court, tribunal, administrative authority, law enforcement agency, regulatory authority or government agency. 


7. Data minimisation
We take every reasonable step to ensure that the personal data we process are adequate, relevant and limited to what is reasonably required in connection with the purposes set out in this Policy. In practice, this means that we collect only the most basic of corporate contact information such as name, job title, company address, switchboard telephone number and company email address. Equally, we do not collect other information such mobile telephone numbers or personal/home email addresses as we do not need them.


8. Data retention and accuracy 
Personal data is stored for varying lengths depending on nature and purpose for which it was collected. 

We review it regularly to ensure it is still accurate and, where necessary, kept up to date. We also take every reasonable step to ensure that any inaccurate information is rectified or erased without delay.

If a person leaves the industry, unsubscribes from an email or wishes that we no longer process their data, their name and contact details are deleted from the database. However, the information may still be used for suppression purposes (i.e. to ensure that it cannot be added to the database again).


9. Processing data for marketing purposes
In addition to the Pharmabase™ data outlined above, Pharmabase Marketing collects contact details of actual or potential customers for our own business and marketing purposes. This is compiled from publicly-available sources; desk/telephone/internet research; enquiries from our website or email communications; incoming email or telephone enquiries; or where there have been previous business dealings. 

Again, we collect only the most basic of corporate contact information such as name, job title, company address, switchboard telephone number and company email address.  

The lawful basis for Pharmabase Marketing to process this personal data is primarily that of our legitimate interests. 

Our marketing to these data subjects comprises occasional email communications (no more than monthly) and as with all our emails, a recipient may unsubscribe from at any time by clicking the ‘unsubscribe’ link at the foot of the email.   


10. Data security
Pharmabase Marketing operates a rigorous data security environment.  We process data in a manner that ensures appropriate security of the personal data and protects against unauthorised or unlawful processing.  We use appropriate technical and organisational measures to protect against accidental loss, destruction or damage.  Data is only provided to selected GDPR-compliant customers that offer legitimate business services, relevant to the professional role of the data subject.


11. Data subject rights
Subject to applicable law, you may have a number of rights regarding the processing of your personal data, including:

  • The right to request access to, or copies of, your personal data that we process or control (This means that you can request from us confirmation of whether we are processing your personal data, and if so, you can have access to that information)
  • The right to request rectification of any inaccuracies in your personal data that we process or control (We are very keen to ensure the data we hold is accurate and up to date and we are happy to correct any errors or omissions)
  • The right to request restriction of your personal data that we process or control. (We value your privacy highly and if you would prefer that we do not process certain parts of your data, then we won’t)
  • The right to request erasure of your personal data that we process or control. (if you would prefer that we do not process your data at all, then we won’t)
  • The right to lodge complaints with a Data Protection Authority regarding our processing of your personal data. (Please talk to us in the first instance so that we can take steps to process your data in a way that is acceptable, but you also have a right to complain to the Information Commissioner if you believe that there is a problem with the way your data is being used)
  • This does not affect your statutory rights. 
  • To exercise one or more of these rights, or to ask a question about these rights or any other provision of this policy, or about our processing of your personal data, please use the contact details provided in section 14) below.
Before we are able to provide you with any information or correct any inaccuracies, we may ask you to verify your identity and to provide other details to help us identify you and respond to your request.


12. Complaints
All complaints or concerns and appropriate resolution relating to the practices of handling personal information will be logged. Any complaints of this nature should be made to: dataprotection@pharmabase.co.uk

Individuals also have a right to complain to the Information Commissioner if they believe that there is a problem with the way their data is being used.


13. Updating the privacy policy
We strive for continuous improvement in our services, processes and protecting data subject rights. We will therefore update this privacy notice from time to time and advise you to check this notice on a regular basis. If requested, we will send you any amended privacy notices on a regular basis and if there are major changes, we will inform you accordingly.  


14. Our contact details
Pharmabase Marketing Limited, 
Aston House, 
24 Hayes Barton, 
Woking, 
Surrey 
GU22 8NH

T: 01483 827814 
E: info@pharmabase.co.uk 
W: www.pharmabase.co.uk

Data Protection Officer: Ciaran Duke
Company Registration No: 07126039
ICO Registration Reference ZA199416



This website


1. Privacy protection
We recognise the need to protect the personal information that might be gathered from our customers, potential customers and visitors to our website. We will only use the information that we collect about you lawfully, in accordance with GDPR. You can access and browse this website without disclosing personal information.

2. Data collection
We collect information about you, to provide you with information about our services. All information is gathered and used solely as part of the service we offer you and is processed and stored in accordance with the requirements of GDPR.
We collect personally identifiable information about you if you register to receive details of special offers on our site; if you purchase any of our products; if you contact us with comments or specific requests; or if you provide a business card or other details to any of our staff.
The elements of your data that we collect may include your name; company name; company email address and telephone number; your email address; and other information specific to the nature of our interaction. We may also collect anonymous information which is not unique to you such as IP address, browser type, access times and referring URL.

3. Data use 
We use your data for the following purposes: to process orders and enquiries, to provide you with information about our products and services, and to inform you about developments in the pharmaceutical and healthcare industries that we believe may be of interest to you.

4. User access and control of your data 
You may request a copy of the personal information we have about you and you may correct it if you wish, using the contact details shown above. If at any time you would like us to stop using your data please contact The Data Protection Officer as above.

5. Cookies
We use cookies to help make it easier for you to access our website. Cookies are pieces of information that a website transfers to your computer's hard disk so that the website can remember who you are. Most websites use cookies. Cookies cannot be used by themselves to identify you. Cookies are also used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. By using our website you agree that we can place these types of cookies on your computer. You may prevent us from storing a cookie on your computer by setting your browser so that it will not accept cookies. 

6. Data disclosure
The data we gather about you from our website will never be sold on to a third party. In certain circumstances, we may need to disclose your data to appropriate third parties if you breach the terms and conditions of use of this website or our services to you. We may also access or disclose your data if required to do so by law or an authorised governmental body.

7. Security
The security of your data is important to us. We have implemented technology and security policies, rules and measures designed to protect the personal data under our control, both on- and off-line, from unauthorised access, improper use, alteration, unlawful or accidental destruction, and accidental loss. Off-line, all of our "personal user data" is restricted in our offices. Only employees of Pharmabase Marketing are granted access to such information. Please remember, however, that no data transmission over the internet can be absolutely guaranteed to be totally secure. While we strive to protect your data as best we can, we cannot ensure or warrant the security of any information which you send to us, or which we store.

8. Other websites
This website contains links to other sites. When you choose to visit those sites, we cannot assume responsibility for any other site's content or information handling practices. We encourage you to review each site's privacy policy prior to entering into transactions with the third party-linked site.

9. Privacy support
If you have any questions or comments about privacy, please contact us. Our details can be found in Section 14 above.

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