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Privacy Policy

In accordance with the General Data Protection Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016 (hereinafter, "GDPR") and Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter, "LOPDGDD") and other applicable regulations, the purpose of this Privacy Policy is to inform all Users who are bound by it of the possible processing of their personal data.

When Users visit the website www.ferrer4future.com or one of its other domains or sub-domains owned by FERRER (hereinafter, "Site" or "Website"), FERRER’s profiles on Social Media (Instagram, Facebook and Twitter, among others) or when they contact FERRER through any of the forms available on the Website, FERRER may process their personal data.

This Privacy Policy is intended for Users to understand what data FERRER collects and what it does with them. To that end, among other things this Privacy Policy explains:

  • what information FERRER collects and for what purposes;
  • how FERRER uses the information;
  • the choices offered by FERRER regarding the information collected.

For the purposes of this Policy, "User" means any category of interested party included in this document.

1. Identification of Data Controller:

GRUPO FERRER INTERNACIONAL S.A. (hereinafter, "FERRER"), in its capacity as the Data Controller, takes the privacy of Users very seriously and makes every effort to respect their privacy.

FERRER's details are:

Owner: GRUPO FERRER INTERNACIONAL, S.A.
Registered address: Avenida Diagonal, nº 549, 5ª Planta, 08029, Barcelona (Spain)
TIN: A61738993
Contact email: lopd@ferrer.com
DPO contact email dpo@ferrer.com
Telephone no.: +34 936 003 700

2. The personal data we process

FERRER collects personal data in the following ways:

  1. Personal data provided by Users: when filling in any of the forms available on the Website, any physical form or through the different FERRER Social Media profiles.
  2. Personal data not provided by Users: sometimes FERRER may collaborate with other institutions, such as IQVIA Information, S.A., through which personal contact data may be obtained from Users, specifically from health professionals. Likewise, data may be obtained from interactions with healthcare professionals, such as, for example, arising from medical visits, delivery of medicines and healthcare products. In any case, these Users will be specifically informed.
  3. Through Cookies and similar technologies: When you visit the Website, FERRER uses different technologies to collect and store information which may include the use of cookies or similar technologies to identify your browser or device. FERRER also uses these technologies to collect and store information when the User interacts with services offered by FERRER or other Google functions that may appear on other websites. Google Analytics helps FERRER analyse website traffic. You can find out more about how FERRER processes the data collected through cookies in our Cookie Policy.

This personal information can generally be grouped into the following categories:

Identification: name, surname, gender, age, ID (DNI or NIF), street address and e-mail address, telephone number, manual and/or electronic signature, marital status, image, voice, social security or mutual insurance number.

Professional and academic data: degrees, languages, medical speciality, medical subspecialties, CV, company or medical centre where you work, position, occupation.

Data for profiling: interests, hobbies.

Connection ID information: IP, logs.

We also process the personal data of different categories of stakeholders, all of whom are considered Users and may include but are not limited to the following groups:

Website and Social Media Users: personal data of Users who contact FERRER through our Website or who access any of our Social Media profiles as a follower, subscriber or independent user.

Healthcare Professionals, Patients/Consumers or Third Party Notifiers: personal data of natural persons who contact FERRER, as well as personal data of natural persons other than those who contact FERRER through our Website to request information and/or ask questions, which may be related to a solution, medical, or to describe an adverse reaction related to pharmacovigilance.

Clients, suppliers or partners: personal data of natural persons who, in their capacity as clients, service providers of any kind or partners, contact FERRER through our Website to build strategic alliances or explore business opportunities, including, but not limited to FERRER's in-license or out-license activities in specific therapeutic areas, requests for technical support and/or oncology diagnostic service.

3. Purposes of data processing, legal basis and term of personal data storage

As mentioned above, FERRER processes personal data obtained from various sources. FERRER also processes personal data according to the different categories of stakeholders and different purposes:

3.1. Purposes of Processing the Data of Website Users

Personal data obtained through the FERRER Website is processed for the following purposes:

1. To respond to requests for information and/or questions asked by Users and to analyse the viability of the proposed solution.

Retention period: until the User's request for information and/or consultation has been resolved and, once resolved, the period of time required to comply with legal obligations, if any.

Lawful basis: the User’s implied consent in his request and/or consultation so that FERRER may respond to it.

3.2. Purposes of Processing the Data of Health Professionals

Personal data obtained by FERRER will be processed for the following purposes:

1. Management of the relationship with health professionals.

Retention period: until the end of the relationship and once ended, the time necessary for the fulfilment of legal obligations is over.

Lawful basis: execution of contractual obligations.

2. In the case of personal data provided when reporting adverse reactions related to medicines, FERRER will process the data for the sole purpose of identifying the notifier, properly managing the response to the stakeholder and reporting the adverse reaction to the competent authorities in accordance with pharmacovigilance obligations.

Retention period: the data will be kept for a period 10 years from the withdrawal of the medication from the last country in which it is marketed.

Lawful basis: compliance with FERRER's legal obligations concerning the reporting of adverse reactions.

3. In the case of personal data provided during a medical consultation, FERRER will process the data for the sole purpose of identifying the notifier and properly managing the response to the Health Professional.

Retention period: a minimum of 10 years and a maximum of 15 years after the information is received.

Lawful basis: compliance with FERRER's legal obligations.

4. Maintain relations of any kind with the legal person in which the health professional provides his services. As well as, those health professionals who are considered individual businessmen or liberal professionals with the purpose of establishing a professional relationship and not as natural persons contacting you, for example, through medical visits with the intention of providing information and training about our products and services.

Retention period: until the objection to the receipt of such communications.

Lawful basis: the legitimate interest of FERRER in accordance with article 19 of the Spanish Data Protection Act as the processing is limited to the data necessary for its professional location and to maintain commercial relations.

5. FERRER informs you that it will publish all payments and value transfers made by FERRER, directly and indirectly, on the Web Site to healthcare professionals.

Retention period: the aforementioned data will remain published for a period of three (3) years from their publication, unless a shorter period is legally established. FERRER will keep the documentation for a period of five (5) years, after which it will proceed to its suppression.

Lawful basis: the legitimate interest of FERRER, in accordance with the report of the Spanish Data Protection Agency of 22 April 2016 and the Code of Good Practice of the Pharmaceutical Industry.

3.3. Purposes of Processing the Data of Patients or Consumers

Personal data obtained by FERRER will be processed for the following purposes:

1. In the case of personal data, including health data, provided when reporting adverse reactions related to medicinal products, FERRER shall process the data exclusively for pharmacovigilance purposes and only when it is relevant and appropriate for documenting, properly managing the response to the data subject and reporting the adverse reaction to the competent authorities, in accordance with pharmacovigilance obligations.

Retention period: the data will be kept until the Patient or Consumer has responded and reported the adverse reaction to Pharmacovigilance.

Lawful basis: your explicit consent given by ticking the appropriate box.

2. In the case of personal data provided, including health data, when sending medical consultations, FERRER will process the data exclusively to attend to requests for information and/or consultations made by the Patient.

Retention period: the data will be kept until the Patient or Consumer has been answered and the case has been documented.

Lawful basis: your explicit consent given by ticking the appropriate box.

3. In the case of personal data provided, including health data, when sending quality claims, FERRER will process the data exclusively in order to attend to your requests relating to quality claims.

Retention period: the data will be kept until the Patient or Consumer has been answered and the case has been documented.

Lawful basis: your explicit consent given by ticking the appropriate box.

3.4. Purposes of Processing the Data of Third Party Notifiers

1. In the case of personal data provided when reporting adverse reactions related to medicines, FERRER will process the data for the sole purpose of identifying the notifier, properly managing the response to the stakeholder and reporting the adverse reaction to the competent authorities in accordance with pharmacovigilance obligations.

Retention period: the data shall be kept until the data subject has responded, documented the case and reported the adverse reaction to Pharmacovigilance and the competent authorities.

Lawful basis: compliance with FERRER's legal obligations concerning the reporting of adverse reactions.

3.5. Purposes of Processing the Data of clients, suppliers or partners

1. To manage User contacts in relation to the operation of FERRER's business; to build strategic alliances or to explore business opportunities, including but not limited to FERRER's in-license or out-license activities in specific therapeutic areas, requests for technical support and/or oncology diagnostic service offered on the Website.

Retention period: until the time when the stakeholder no longer wishes to receive such communications.

Lawful basis: the legitimate interest of FERRER in accordance with article 19 LOPDGDD, as the processing is limited to the data necessary to maintain professional and commercial relations.

2. To maintain relations of any kind with the legal entity where the affected party works and also with individual entrepreneurs or independent professionals in order to establish professional relationships with them.

Retention period: until the time when the stakeholder no longer wishes to receive such communications.

Lawful basis: the legitimate interest of FERRER in accordance with article 19 LOPDGDD, as the processing is limited to the data necessary to maintain professional and commercial relations.

3. To keep FERRER’s customers informed, including electronically, about FERRER’s products and services and news related to those products and services similar to the ones contracted by the User.

Retention period: until the time when the stakeholder no longer wishes to receive such communications. When the User orders a product and/or services, there will be a mechanism available to the user to oppose these types of commercial communications.

Lawful basis: FERRER’s legitimate interest in accordance with article 21.2 of Act 34/2002 of 11 July on information society services and e-commerce (LSSI), since there is a prior contractual relationship through which FERRER lawfully obtained the contact details of its customers which it uses to send commercial communications regarding products or services similar to the ones originally ordered by the User.

3.6. Purposes of processing the data of Social Media Users

1. To manage the User's interactions with FERRER through the different Social Media profiles (Instagram, Facebook or Twitter, among others). The data processed for this purpose is the information entered by Users in their social media profiles and therefore regulated by the Privacy Policies of those social media networks, for which FERRER is not responsible.

Retention period: the data processed for this purpose will be retained for as long as FERRER maintains the social media profile.

Lawful basis: the implicit consent of the stakeholder given when interacting with and/or following FERRER’s social media profile.

3.7. Purposes of processing that are common to all of the foregoing stakeholder categories

1. To keep the stakeholder informed, including electronically, about FERRER’s products, services, news, publications, invitations, programmes, newsletters, activities and events, provided that the User has expressly consented to such processing.

Retention period: until the time when the stakeholder withdraws his/her consent to receive such communications.

Legal basis

i. The explicit consent of the stakeholder to receive such communications.

4. Recipients

In accordance with the purposes for processing indicated above, the personal contact details of the Website’s users, customers, suppliers or partners will be disclosed to the companies of the FERRER Group as long as they have explicitly consented to such disclosure and, failing that, on the basis of FERRER’s lawful interest for internal administrative purposes in accordance with recital 48 GDPR in relation to customers and candidates. The details of FERRER Group companies are available upon request at comunicacion@ferrer.com.

You are also informed that the personal data of health professionals, patients or third party notifiers will be disclosed in the event of adverse reactions that must be reported to the Spanish Pharmacovigilance System for Medicinal Products for Human Use (SEFV-H).

You are also informed that your personal data may be accessed by third parties acting on behalf of FERRER, provided that such data access and processing is essential for the provision of a specific service to FERRER. Should such a scenario arise, FERRER shall in any event enter into the relevant data processing contracts with each of these third parties, which shall solely process these data for the purposes that FERRER determines in each case.

In order to send notices electronically, we may use the Gmail or Google Drive platform which implies transferring the User's data to a processor located in the United States, Google LLC, the owner of the platform, which is a member of Privacy Shield (www.privacyshield.gov) in relation to the protection of personal data. Google also collects connection data (including your email and IP address) through its tracking technologies, which may also be transferred.

5. International Transfers

For some services, the personal data of certain categories of data subjects may be processed, accessed or stored in a country other than the one where FERRER is located, which may not offer the same level of protection for personal data.

If FERRER transfers personal data to external companies in jurisdictions outside the European Economic Area, it will ensure the protection of personal data (i) by applying the level of protection required under local data protection/privacy legislation applicable to FERRER, (ii) by acting in accordance with FERRER's standards and policies, and (iii) for FERRER, located in the European Economic Area (i.e. EU member states plus Iceland, Liechtenstein and Norway, the "EEA"), unless otherwise indicated, only transferring personal data in accordance with standard contractual clauses approved by the European Commission and (iv) seeking the consent of the data subject where the lawful basis for processing is concerned.

You may request additional information regarding international transfers of personal data and obtain a copy of the relevant protection measures that have been implemented by exercising your rights as detailed below in paragraph 7 (Rights).

6. Security and Access

In accordance with GDPR and LOPDGDD, FERRER applies technical, administrative and organisational security measures to protect the data we collect against accidental or unlawful destruction or loss and unauthorized alteration, disclosure or access, in particular when the processing involves the transmission of data over a network, and against any other unlawful form of processing.

Generally speaking, in order to access and browse the contents of the Website it is not necessary for the User to be registered. However, the visibility of certain Social Media content may be contingent upon the User’s prior registration. In this case, the data entered by the User must be accurate and current and the User must abide by the social network’s Privacy Policy.

7. Rights

Users may exercise the following rights with FERRER in relation to their personal data: access; correction, erasure, restriction of processing; data portability and opposition.

Furthermore, the processing of the User’s personal data is legitimised by the express consent given by the interested party, who may withdraw her/his consent at any time, without this affecting the lawfulness of the processing based on her/his consent before it was withdrawn.

To exercise these rights, the data subject party may send his/her request in writing, along with proof of identity, specifically indicating which of the aforementioned rights he/she is exercising:

(i) By email to lopd@ferrer.com

(ii) By post addressed to GRUPO FERRER INTERNACIONAL S.A. at Av. Diagonal nº 549, 5ª planta, 08029, Barcelona.

We shall examine all requests and submit a reply within the period of time established by the laws in force. Please note, however, that certain information may be exempt from such requests under some circumstances if it includes personal data that we need to continue to process for our own legitimate interests or to comply with a legal obligation.

In any event, the User is entitled to file a complaint with the relevant supervisory authority should she/he deem fit.

If you have any questions regarding the processing of personal data by FERRER, you can contact our Data Protection Officer at the following e-mail address: dpo@ferrer.com

8. Changes or modifications to our privacy policy

We may revise this Privacy Policy from time to time and post the most current version on our website. We will inform you if your rights are materially affected as a result of such a revision.