PHARMAnetwork Limited understands the importance of maintaining the confidentiality of any information you may provide while using the site and the PHARMAnetwork magazine web and apps edition.

Under the European Union directive known as the General Data Protection Regulation ("GDPR") which is due to be incorporated into UK law by the Data Protection Act 2018, we, as the data controller in respect of that personal data, are required to provide you with a set of specific information about how we will use, hold and retain this data as well as making you aware of various rights that you have under the related legislation. We have set this information out below in this policy.

Should you have any queries about the manner in which we process your personal data please contact:
Pharmanetwork Ltd. a company registered in England and Wales under company number 10807134 whose registered office is at Lincoln House 4th Floor, 300 High Holborn, London, United Kingdom, WC1V 7JH
Email: info@pharmanetwork.com

Why we process your personal data?
We process your personal data for the following purposes:

• the provision to you of cross platform digital publishing solutions and services ("Publishing Services"); and
• in order to provide you with marketing information, updates and publications relating to the services we offer and other related information ("Marketing Services").

The legal basis on which we process your personal data
In respect of the provision of Publishing Services, our processing is based on the lawful basis that it is necessary for us to process your personal data in order to provide you with the Publishing Services we are contracting with you to provide (or which we are in discussions to provide you with).
We may also need to process your personal data in order to comply with legal obligations to which we are subject.
In respect of Marketing Services, we will only use your personal data to provide you with marketing information, promotions and information about issues that we feel you may be interested in where you have given us your specific consent to do so or where there is a legitimate interest.

Opting out of Marketing Services
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, you may not be able to access certain features of our Publishing Services.

Is it a legal (statutory or contractual) requirement for you to provide us with your personal data?
If you fail to provide certain information when requested, we may not be able to perform any contract we have entered into with you or we may be prevented from complying with our legal obligations.

Who do we pass/share your personal data with?
We may share your personal data with the parties set out below.

• We may pass your personal data to our third party service providers, subcontractors for the purposes of completing tasks and providing services to you that we have agreed to provide. When we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your personal data secure and to keep it in accordance with the requirements of UK data protection law and not to use it for their own direct marketing purposes.
• We may transfer your personal information to a third party as otherwise permitted by UK data protection law, for example to our legal advisors or in order to comply with a legal requirement or obligation placed on us by law.

Other than as referred to above, PHARMAnetwork will never sell or share personal information with third parties.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Do we pass your personal data outside of the European Union?
Some of our external third parties are based outside the European Economic Area ("EEA") so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

How long do we keep your personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

What are your data protection rights?
As a "data subject" under the data protection legislation you have a set of specific rights. We are required to make you aware of the existence of these rights. They are in outline:

• the right to request from us, as the data controller, access to your personal data;
• the right to request rectification of your personal data;
• the right to request erasure of your personal data;
• the right to request a restriction on the processing of your personal data;
• the right to object to the processing of your personal data; and
• the right to data portability.

For further details on these rights, when they apply, how to exercise them and the exemptions and wider rules and requirements that apply to such rights please visit the Information Commissioner's website at www.ico.org.uk.

Your right to withdraw consent where processing is based on consent
Where any part of our processing of your personal data is based on your consent you may withdraw your consent to that processing at any time.

Your right to complain to the Information Commissioner's Office
If you are unhappy with how PageSuite is using your personal data we would encourage you to raise this concern with our Data Protection Officer.
You have the right to lodge a complaint about our compliance with the UK data protection legislation with the applicable regulator for data protection. This is the Information Commissioner's Office. For more information you can visit their website at www.ico.gov.uk

Use of automated decision making or profiling
We do not carry out automated decision making or profiling.

The data we collect about you and how we collect it
General information
In general, we gather information about all of our users collectively, such as what areas of this website are visited most frequently and which of our services are accessed the most. We only use such data in an aggregate form. This information helps us determine what is most beneficial for our users, and how we can continually create a better overall experience for you.
Please note, we may record calls for training and monitoring purposes.

Unique Device Identification (UDID's) for Apple and Android applications and how we use them
PageSuite uses a UDID collection service for all of our apps. The data is completely anonymous. The UDID capture is used ONLY for restoration of subscriptions and previous purchases. Unlike many other mobile applications, we do not use this unique identifier to push any other services, whether it be advertisements, purchasing history, likes/interests etc. This service is purely for restoration of items and subscriptions you may have purchased.

Google Play account Email Address for Android applications and how we use them
Within our android apps we will ask to access your Google Play Account's email address; this data is requested to be used for both the restoration of subscriptions and previous purchases as well as when making a new subscription or purchase. PageSuite does not use this for any marketing or profiling services and it is never shared with any third party.

Cookies
A cookie is a harmless piece of information that a website transfers to the cookie file of the browser on your computer's hard drive. On visiting the website, a cookie will be placed on your computer automatically by the website. PHARMAnetwork may use two types of cookie from time to time: "persistent cookies" and "session cookies". Session cookies are temporary cookies that remain in the cookie file of your browser until you leave the website and persistent cookies are cookies which remain in the cookie file of your browser for much longer (though for how long will depend on the lifetime of the specific cookie). For more information regarding the use of cookies go to www.aboutcookies.org. PHARMAnetwork does not use its persistent or session cookies to store personal information about you.

PHARMAnetwork uses its cookies for internal research and to give a better understanding of our audience including monitoring load balancing between its servers while you are linked to the website, to conduct analyses of user traffic, and to perform web log audits. Third party advertisers may serve cookies via this website but these are only used to serve advertisements from the website's ad servers and to track whether these advertisements are clicked on by visitors to the website. PHARMAnetwork may pass the non-personal information collected by its cookies to third parties but only for the purposes of carrying out such monitoring, analysis or web log auditing, or for the purposes of tracking the number of anonymous users of the website.

Most browsers accept cookies automatically but you have the ability to accept/decline cookies by altering the settings in your browser. If you decline/disable cookies, you may not be able to use all the interactive features of the website or the website may not be available to you.

Security
The website is protected against unauthorised access using the latest security devices and firewalls.

Third party-links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. You should also be aware that if you link out to third party websites, they have their own privacy policies for which PageSuite can accept no responsibility. Please be certain to check other sites before use.

Changes to the privacy policy
We reserve the right to add to or change the terms of this privacy policy in our sole discretion, without prior notice to you. If we change this privacy policy, we will post the new privacy policy on the website, and it will become effective from the time of posting to the website. Please visit this privacy policy on a regular basis to make sure you have read the latest version and you understand what we do with your information. This version was last updated on [20.12.19].

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.