For the purposes provided by Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 regarding the protection of natural persons with regard to the processing of personal data and the free circulation of this data (hereinafter, “GDPR”), and by Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (“LOPDGDD”), you are informed of the following aspects:
1. DATA CONTROLLER
We inform you that SOM INNOVATION BIOTECH, SA, (hereinafter, “SOM BIOTECH”), with address at Calle Baldiri Reixac, nº 4, 08028, Barcelona (Spain), Tax Identification Code: A65243016, and registration data registered in the Commercial Registry of Barcelona, Volume 46564, Page 0202, Sheet 392808, is the data controller for the processing of your personal data.
You can contact us through the postal address indicated, or at the email address: email@example.com
2. WHAT PERSONAL DATA WE PROCESS FROM YOU, HOW WE HAVE OBTAINED IT AND WHAT WE PROCESS IT FOR
i. If you are a patient or an interested party in the activities and Services of SOM BIOTECH and have made a query in relation to said services and activities.
The personal data subject to processing is the data you have provided us in accordance with your request or requirement for information regarding the projects that SOM BIOTECH develops.
The processing of your personal data may include the health data that you have provided us with in accordance with your request or request for information. SOM BIOTECH only processes your health data in order to attend to your requests for information, protected by the regulations related to patients and biomedical research, always keeping the strictest confidentiality and security for the custody of said data.
ii. If you work or provide your services in favour of suppliers, clients or other legal entities that are related to SOM BIOTECH due to their activity.
The data we have about you has been obtained through the professional, commercial or contractual relationships that you or the company, entity or organization for which you work or collaborate has maintained (or currently maintains) with SOM BIOTECH. This data consists of your corporate contact information: name, surname, telephone number and corporate email.
The data that we will process about you is limited to your corporate contact data, with the sole purpose of being able to maintain commercial, contractual or collaborative relationships that SOM BIOTECH maintains with you or the company, entity or organization for which you work or collaborate with. Said processing responds to a legitimate interest of our entity, expressly recognized by the privacy regulations.
iii. If you have subscribed to our newsletter or participated in our activities or obtained our services.
SOM BIOTECH processes your identification data (name, surnames, email) and your contact data (address, telephone, email). Your data has been obtained by having provided it to us by sending the contact form in order to make a request to obtain information related to the services and activities that SOM BIOTECH carries out by reason of its activity.
SOM BIOTECH processes your personal data to send you, by electronic means, information and communications about the activities that SOM BIOTECH carries out in which you have participated or shown your interest, according to your subscription request to our newsletters.
In any case, you may oppose the receipt of subsequent communications by electronic means and as referenced in the section “WHAT ARE MY RIGHTS” of this policy.
Likewise, we inform you that in order to send these communications we will process your personal data through tracking pixels in order to measure the success of our commercial communications and/or newsletter among the users who receive them.
iv. If you are a follower of SOM BIOTECH in our profiles on Social Networks.
SOM BIOTECH has profiles on social networks (for example, on Twitter, LinkedIn and YouTube), therefore, it may act as co-controller for the processing together with said owners of social networks, we provide links to the privacy policies of these providers below:
(i) Twitter: https://twitter.com/es/privacy
(iii) YouTube: https://policies.google.com/privacy?hl=es&utm_source=ucb
Likewise, we inform you that we cannot be held responsible for the processing of personal data carried out by these holders. In this sense, SOM BIOTECH will only be responsible for its own data processing, described in the clause.
In this case, we inform you that we process your identification data (name and surname), contact data (email address), social network account ID in order to manage the interactions between you and SOM BIOTECH through the information provided by you in the social networks in which SOM BIOTECH has an active profile.
In addition, FACEBOOK processes your personal data as established in the applicable Product Terms. More information on how FACEBOOK processes personal data, including the types of data, purposes, and legal bases on which FACEBOOK is based, can be found in the FACEBOOK Data Policy at https://www.facebook.com/about/ privacy
v. If you are an investor of SOM BIOTECH in accordance with our conditions and access on the website
SOM BIOTECH processes your identification data (name, surnames, email) and your contact data (address, telephone, email). Your data has been obtained by having provided it to us by registering as an investor in order to support the objectives and services of SOM BIOTECH.
SOM BIOTECH processes your personal data to send you, by electronic means and through access to our platform, information and communications about the activities and financial information of SOM BIOTECH in which you have participated or shown your interest, according to your request.
In any case, you will receive, if you are an investor, more detailed information about the processing of your data, as well as more specific information about the use of our platform and services to which you will have access.
3. WHY WE CAN PROCESS YOUR PERSONAL DATA
i. If you are a patient or an interested party in the activities and Services of SOM BIOTECH and have made a query in relation to said services and activities
The processing of your personal data is legitimized for the purposes detailed below:
If you have requested information about our projects or have contacted us, we will process your data in order to respond to your request. In the event that you have provided us with health or special category data in your request, the processing of your data by SOM BIOTECH will be covered by compliance with the regulations related to patients and biomedical research.
SOM BIOTECH also processes your personal data necessary for the fulfilment of its legal and/or regulatory obligations.
ii. If you work or provide your services in favour of suppliers, clients or other legal entities that are related to SOM BIOTECH due to their activity
The processing of your data in order to maintain the commercial, contractual or collaborative relationships that SOM BIOTECH maintains with you or the company, responds to a legitimate interest of our entity, expressly recognized by the privacy regulations.
iii. If you have subscribed to our newsletter or participated in our activities or obtained our services
The processing of your personal data for the purposes described above, is legitimized by the fulfilment of the contractual relationship between you and SOM BIOTECH, according to your subscription request to our newsletter.
Likewise, the processing of your personal data to send you information and communications about activities of a similar nature to which you have shown your interest, is expressly authorized by current regulations.
In any case, you may oppose the receipt of further communications by electronic means and in accordance with what is referred to in the section “WHAT ARE MY RIGHTS” of this policy.
The processing of your personal data related to tracking technologies is legitimized by the consent you give us by checking the box or subscribing to the commercial communications form or the newsletter form, where appropriate.
You may withdraw your consent and unsubscribe from these communications or newsletters at any time.
You can also object to the download of these technologies by disabling the automatic downloading of images through your email provider.
iv. If you are a follower of SOM BIOTECH in our profiles on Social Networks.
The processing of your personal data is legitimized as it is necessary to comply with the contractual or pre-contractual obligations established in the Terms and Conditions applicable to each active profile of SOM BIOTECH in third-party social networks.
v. If you are an investor of SOM BIOTECH in accordance with our conditions and access on the website
The processing of your personal data is legitimized as it is necessary to comply with the contractual or pre-contractual obligations, as well as legal, established in the conditions applicable to each investor, further details will be given to you when registering as an investor.
4. AUTOMATED DECISIONS
SOM BIOTECH does not make decisions that may affect you based solely on the automated processing of your personal data. All decision-making processes related to the processing purposes described above are carried out with human intervention.
5. ASSIGNMENTS TO THIRD PARTIES
SOM BIOTECH may provide your personal data to Public Administrations and auditing companies for the strict fulfilment of the obligations to which SOM BIOTECH is subject due to its activity. In addition, SOM BIOTECH will also provide your data to Security Bodies and Forces when required to provide this information in compliance with a legal obligation.
Likewise, our company informs you that your data may be transferred to service provider companies with which SOM BIOTECH has signed the corresponding contracts, applying all the necessary guarantees and safeguards to preserve your privacy.
In the event that SOM BIOTECH needs to make other communications of your personal data, we will previously request your consent.
6. INTERNATIONAL TRANSFERS
SOM BIOTECH may contract the services of suppliers located in countries outside the European Economic Area, based on adequacy decisions of the European Commission. In this case, it is considered that the country has regulations equivalent to the European one. In the case of SOM BIOTECH needs to contract services from suppliers located in countries that do not have regulations equivalent to the European one, the contracting will include all the guarantees and safeguards required by the regulations to preserve your privacy, after verifying the legislation of the destination country.
These safeguards may consist of the application of contractual clauses and additional guarantees to them, in accordance with the regulations of each country of destination, or of binding corporate regulations approved by the data protection authorities. We also inform you that the regulations allow us to send your data to said countries, if it is necessary to comply with our obligations derived from the service that you request from us.
Mailchimp: The Rocket Science Group, LLC 675 Ponce de Leon Ave NE Suite 5000. Atlanta, GA 30308 USA. Features. Provider of newsletter delivery tools.
For more information about the guarantees on your privacy, or about the destination countries to which we need to transfer your data to fulfil our contractual obligations with you, you can contact us through the postal and electronic addresses indicated below.
7. SECURITY MEASURES
To guarantee security on our page, we have integrated a security system that allows us to maintain the confidentiality and integrity of our users’ data that has been sent or collected through the means mentioned in the second point.
This way, SOM BIOTECH maintains the security levels of data protection required by the LOPDGDD and the GDPR. Also, as a user of our website, you understand and accept that the security measures on the Internet are not impregnable and that, therefore, you are obliged to adopt the necessary security measures that allow you to trust the veracity of our web page, in which you are entering your data. We will also do everything possible to guarantee the privacy and security of your personal data at all times, always using the utmost diligence and implementing the necessary measures.
Thus, we inform you that you will be solely responsible for the security measures that you implement in relation to the protection of your data, with which SOM BIOTECH is not responsible for situations where the User has not implemented the corresponding security measures, nor of its consequences, nor for causes or damages caused by third parties unrelated to the business, including fortuitous events and/or force majeure.
In accordance with the foregoing, SOM BIOTECH cannot guarantee that unauthorized third parties may have knowledge of the class, conditions, characteristics and circumstances of the use that users make of the services offered on the website. However, as a measure, some conditions of use have been provided in our Legal Notice.
Those who provide data through the form or corporate emails, or other means on the website, and, who accept their data processing, declare to be over 18 years of age, access and use of the website to minors is prohibited.
If at any time we detect that a person under 18 years of age has provided personal data, we will proceed to cancel their data.
9. HOW LONG WILL WE KEEP YOUR DATA
Your personal data will be kept as long as your relationship with SOM BIOTECH is maintained and, after the termination of said relationship for any reason, during the applicable legal prescription periods. In this case, they will be kept blocked, adopting the appropriate technical and organizational measures to prevent their processing, including their display, and being only available to judges, courts, prosecutors or public administrations, all in order to deal with legal responsibilities, if any. Once said limitation periods have expired, your data will be deleted or, alternatively, anonymised.
10.WHAT ARE YOUR RIGHTS
We inform you that you have the right to access your personal data, rectify inaccurate data, request its deletion when the data is no longer necessary, request opposition or limitation of its processing or request its portability, by writing to SOM BIOTECH through the following addresses:
- Postal address: Calle Baldiri Reixac, nº 4, 08028, Barcelona (Spain)
- Electronic address: firstname.lastname@example.org
Below, we will explain what your rights regarding the processing of your personal data consist of:
Through the exercise of this right you can know what personal data of yours is being processed by us; its purpose, origin or possible transfer to third parties.
It consists in that you can modify your personal data that are inaccurate or incomplete, and you must specify in the request what data you want to be modified.
It allows the cancellation of your personal data for inadequate or excessive.
With the right of opposition, you can oppose the processing of your data in cases such as: advertising and commercial prospecting activities or when said processing is intended to make a decision about you based solely on automated processing of your personal data.
You will be able to receive your personal data provided in a structured format, of common use and mechanical reading, and be able to transmit it to another data controller, whenever it is technically possible
You may request the deletion of personal data without due delay when any of the cases contemplated occurs. For example, illicit data processing, or when the purpose that motivated the processing or collection has disappeared.
Limitation on the processing
In general, in cases where it is not clear whether personal data should be erased, you can exercise your right to limit its processing. This right exists in the following cases: (i) when the accuracy of the data in question is in doubt; (ii) when as a User you do not want the data to be deleted, (iii) when the data is no longer necessary for the original purpose, but cannot be deleted for legal reasons, (iv) when the decision of your objection to the processing is pending.
Limitation means that once this right has been exercised, your personal data can only be processed if you grant your consent or if there is a legal obligation that provides or allows it, such as in cases of data retention by legal imperative, or for the formulation, exercise or defense of claims, or with the aim of protecting the rights of another natural or legal person or for reasons of public interest of the EU or of a certain Member State of the EU. As a User, you must be informed before the lifting of said limitation.
Not to be subject to automated individual decisions
You will have the right not to be the subject of a decision based solely on automated processing, including profiling, that produces legal effects on you or similarly significantly affects you.
If you consider that the processing of your personal data violates the regulations, you can:
(i) Submit a claim through the postal and electronic addresses indicated above, or;
(ii) Submit a claim to the Spanish Data Protection Agency, through its postal address: C/ Jorge Juan, 6, C.P. 28001, Madrid (Spain), or, accessing the website www.aepd.es.
SOM BIOTECH reserves the right to modify this policy to adapt it to future legislative or jurisprudential developments. In the event that said modification affects you in relation to the processing of your data, for example, because some additional processing is going to be carried out, not previously informed, we will proceed to notify you about it.
13.INTEGRATION WITH THE REST OF THE LEGAL TEXTS
Last update: April 11, 2022
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