GP PHARM, S.A. processes personal data to carry out its main activities in the pharmaceutical sector. GP PHARM, S.A. considers the protection of your personal data to be a matter of the utmost importance.

The management of GP PHARM, S.A. has the firm decision to ensure compliance with the legislation on data protection and thus ensure the legal rights and proper management of personal data.

To this end, GP PHARM, S.A. has equipped itself with a management system that guarantees:

1. The lawfulness of the data, establishing an adequate purpose with the processes for which they are collected, to comply with the lawful objectives of GP PHARM, S.A.
2. Collect the strictly necessary data, informing the interested parties as established in the legislation. Depending on the method of collection, the data that will be collected through the corresponding forms, will only contain the essential fields to be able to carry out its treatment according to the purpose informed to the owner of the data.
3. The exercise of the legal rights of the interested parties.
4. The confidentiality of personal data throughout the processing process and compliance with the obligation of secrecy with respect to personal data.

As part of this system, we put at your disposal the common elements for all the treatments on the personal data that are treated in GP PHARM, S.A., as responsible for the treatment.

1. Identification of the owner

The domain http://gp-pharm.com/ is owned by GP PHARM, S.A., a company of the Volsunga Group, domiciled in Polígono Industrial Els Vinyets-Els Fogars, sector 2, Carretera C44, 08777 Sant Quintí de Mediona (Barcelona)- Spain, Tax ID: A62408786, registered in the Mercantile Registry of Barcelona in Volume 33047, Folio 109, Page B220897, Inscription 1ª and e-mail address rgpd@bcncorp.com.

General conditions of use

The use of this website is subject to the following General Conditions of Use. Please read them carefully and do not use the website unless you accept these General Conditions, as access and use of the website implies full acceptance by the user of these general conditions in the version published on the website at the time of access.

The content of this website is for information purposes only and GP PHARM, S.A. does not guarantee the accuracy or completeness of the information contained or referenced in this website. Please note that the materials contained on the website may not reflect the most recent information on the products and/or services offered by GP PHARM, S.A. Likewise, these materials may be modified, developed or updated without prior notice. Please be advised that some of the products described on the website are still under clinical development and are not currently available for prescription.

The user agrees to access the website and its content at user’s own risk. GP PHARM, S.A. is not responsible for any errors or omissions in the contents of this website, GP PHARM, S.A. informs that these contents are merely informative and are not intended to replace in any case the consultation of the physician. Consequently, GP PHARM, S.A. is not responsible for the decisions taken by the user based on the information on health care, diseases and medical treatments provided through the website, nor for the damages caused to the user or third parties, due to actions based on the information obtained from the website.

The user is obliged to use the web site only and exclusively for personal purposes and, therefore, will not exploit it commercially, being under his responsibility the access and use of the same.

GP PHARM, S.A. does not guarantee the absence of viruses or other harmful elements that may cause damage or alterations to the computer system, electronic documents or files of the user of this website. Consequently, GP PHARM, S.A. is not liable for damages that such elements may cause to the user or third parties.

Any change in these general conditions of use will be communicated in a timely manner on this website.

2. Data protection

GP PHARM, S.A. is responsible for the treatment of the user's personal data and informs you that these data will be treated in accordance with the provisions of the current regulations on data protection.

GP PHARM, S.A. collects personal data when you visit our website. The specific data that GP PHARM, S.A. collects about you are those data that you provide in case there are data collection forms, the data that you can send when using the contact sections and those data related to the application you use.

Below, we inform you about the treatments and their main purposes currently carried out by GP PHARM, S.A.:

Purpose of processing:

The operations envisaged to carry out the processing are:

• Sending of commercial advertising communications, as long as it has been previously authorized, by email, fax, SMS, MMS, social communities or any other electronic or physical means, present or future, which makes possible to carry out commercial communications. These communications will be made by GP PHARM, S.A. and related to its products and services, or those of its collaborators or suppliers with whom it has reached a promotional agreement. In this case, third parties will never have access to personal data.
• To process orders, requests or any type of request made by the user through any of the forms of contact that are made available to the user.
• Sending the newsletter of the website.
• Manage and improve our website.
• Measure the use of our website.
• Improve the quality of our products and services and expand our business activities.
• To monitor and prevent fraud, infringement, and other potential misuse of our website.
• In case the career or job search functionality is activated, your data will be used for the main purpose of personnel management and selection. Whether you submit your resume electronically and/or through a web form, your data will be treated confidentially and for the sole purpose of processing your application.
• In social networks, we will treat your data to properly manage your presence in the relevant social network, inform you of our activities, products and / or services, or third parties that may be related to our activity, as well as for any other purpose that the regulations of the Social Networks may allow.
• To respond to an official requirement of a public or judicial authority with the necessary authorization.
• To preserve the economic interests of the company and to ensure compliance and reporting.
• Archiving and record retention.
• Any other purpose imposed by law and authorities.

We will not process your personal data if we do not have an appropriate justification under the law for doing so. Therefore, we will only process your personal data:

• If we have obtained your prior consent.
• If the processing is necessary to fulfill contractual obligations, we have entered into with you or to take pre-contractual measures if you so request.
• If the processing is necessary for us to comply with our legal or regulatory obligations.
• If the processing is necessary for our legitimate interests and does not unduly affect your interests or fundamental rights and freedoms.

The transmission of data will take place in encrypted form. In case of any changes to your data, please inform us in writing as soon as possible, in order to keep your data up to date.

Data retention criteria:

Data will be retained for as long as there is a mutual interest in maintaining the purpose of the processing and when it is no longer necessary for that purpose, it will be deleted with appropriate security measures to ensure the pseudonymization of the data or the total destruction of the data.

Unless otherwise stated the retention period is thirty-six (36) months from your last use of/access to the relevant website or application. At the end of this period, your personal data will be deleted from our active systems.

Data recipients:

Unless legally required, GP PHARM, S.A. expressly informs and guarantees users that their personal data will not be disclosed under any circumstances to third parties, and that whenever any type of transfer of personal data is carried out, the express, informed, and unequivocal consent of the users will be requested beforehand.

In the event that the recipient of the data is a third party (such as transfer of In the event that the recipient of the data is a third party (such as transfer of data between companies of the Volsunga Group) or utilization of suppliers to provide auxiliary services for our activity, which may have access to personal data, GP PHARM, S.A. will try to implement adequate guarantees of data protection, such as the signing between the parties of standard contractual clauses or adoption of binding corporate rules between the companies of the group.

During the course of our activities and for the same purposes as described above, your personal data may be consulted by the following categories of recipients, if they need to know them, in order to fulfill those purposes:

• Our staff (including staff, departments, or other companies of the Volsunga group).
• Our service providers, IT systems, cloud service providers, database providers and consultants.

The third parties listed above are contractually obliged to protect the confidentiality and security of your personal data, in compliance with applicable law.

Your personal data may also be accessed by, or transferred to, national and international regulatory, law enforcement, public or court agencies, either when we are required to do so by applicable law or regulation or upon their request.

The personal data we collect from you may also be processed, accessed or stored in a country other than the country in which GP PHARM, S.A. is located, which may not provide the same level of protection for personal data.

International Transfers:

In case of international transfers of data to third countries outside the European Union, we will try to implement other appropriate data protection safeguards, such as the signing of standard contractual clauses between the parties or the adoption of binding corporate rules between the group companies, which means that they are obliged to comply with equivalent requirements to the European ones in terms of data protection.

Rights of the user:

• Right to withdraw consent at any time.
• Right of access, rectification, portability and deletion of their data and the limitation or opposition to its processing.
• You may revoke your consent to receive commercial communications at any time by sending your request to the e-mail address rgpd@bcncorp.com.
• The right to file a complaint with the supervisory authority (aepd.es) if you consider it necessary, especially when you have not obtained satisfaction in the exercise of your rights.

To exercise these rights can be addressed by sending a letter including in the same reference "Data Protection" which specifies the corresponding request and accompanying photocopy of ID.

Contact details to exercise your rights:

Postal address: GP Pharm, S.A., Pol. Ind. Els Vinyets-Els Fogars, sector 2, Carretera C44, 08777 Sant Quintí de Mediona (Barcelona)- Spain.

E-mail address: rgpd@bcncorp.com

Users, by ticking the corresponding boxes and entering data in the fields marked with an asterisk (*) in the contact form, expressly and freely and unequivocally accept that their data are necessary to meet their request, by the provider, being voluntary the inclusion of data in the remaining fields.

The user guarantees that the personal data provided to GP PHARM, S.A. are truthful and is responsible for communicating any changes to them. All data requested through the website are mandatory, as they are necessary for the provision of an optimal service to the user. If all the data are not provided, there is no guarantee that the information and services provided will be completely tailored to your needs.

3. Security measures

GP PHARM, S.A. is complying with the current regulations on data protection and declares that the data are treated in a lawful, loyal and transparent way in relation to the interested party and adequate, pertinent and limited to what is necessary in relation to the purposes for which they are treated.

GP PHARM, S.A. guarantees that it has implemented appropriate technical and organizational policies to apply the security measures established by current data protection regulations, to protect the rights and freedoms of users and has provided them with the appropriate information so that they can exercise them. To ensure confidentiality in the storage and processing of personal data, as well as to prevent access by unauthorized third parties, and its alteration, loss or unauthorized processing.

4. Property rights

The web sites, including but not limited to its programming, edition, compilation, and other elements necessary for its operation, designs, logos, text and/or graphics, are property of GP PHARM, S.A. or, if it is the case, it has a license or express authorization from the authors. All the contents of the web site are duly protected by Spanish, European and international intellectual and industrial property regulations, as well as registered in the corresponding public registers.

Regardless of the purpose for which they were intended, the total or partial reproduction, copy, use, exploitation, distribution, transformation, commercialization and any other activity that can be carried out with the information contained in this website, requires in any case the prior written authorization by GP PHARM, S.A. Any use not previously authorized is considered a serious breach of the intellectual or industrial property rights of the author.

The designs, logos, text and/or graphics not belonging to GP PHARM, S.A. and that could appear in the web site, belong to their respective owners, being themselves responsible for any possible controversy that could arise regarding them.

GP PHARM, S.A. recognizes in favor of their owners the corresponding intellectual and industrial property rights, and their mere mention or appearance on the web site does not imply the existence of any rights or responsibility whatsoever over them, nor any endorsement, sponsorship or recommendation by the same. To make any comments regarding possible breaches of the rights of intellectual or industrial property, as well as any of the contents of the website, you can do so via email rgpd@bcncorp.com.

5. Exemption of responsibilities

GP PHARM, S.A. is exempt from any type of responsibility derived from the information published in its web site whenever this information has been manipulated or introduced by a third party external to the same.

Link Policy

From the websites, it is possible to be redirected to contents of third-party websites. Given that GP PHARM, S.A. cannot always control the contents introduced by third parties in their respective websites, it does not assume any type of responsibility with respect to such contents. In any case, it will proceed to the immediate withdrawal of any content that could contravene national or international legislation, morality, or public order, proceeding to the immediate withdrawal of the redirection to said website, informing the competent authorities of the content in question.

GP PHARM, S.A. is not responsible for the information and contents stored, including but not limited to, in forums, chats, blogs generators, comments, social networks or any other means that allow third parties to publish contents independently in the GP PHARM, S.A. website. However, and in compliance with the provisions of the current regulations of the Information Society, it is available to all users, authorities, and security forces, actively collaborating in the removal or, where appropriate, blocking of all content that may affect or contravene national or international law, the rights of third parties or morality and public order. In the event that the user considers that there is any content on the websites that could be susceptible to this classification, please notify the website administrator immediately.

The websites have been checked and tested to ensure that they function correctly. In principle, proper functioning can be guaranteed 365 days a year, 24 hours a day. However, GP PHARM, S.A. does not rule out the possibility of certain programming errors, or the occurrence of force majeure, natural catastrophes, strikes or similar circumstances that make it impossible to access the website.

IP Addresses

Web site servers may automatically detect the IP address or domain name used by the user. An IP address is a number automatically assigned to a computer when it connects to the Internet. All this information is recorded in a file of activity of the service duly registered that allows the subsequent processing of the data to obtain measurements only statistics that allow to know the number of page impressions, the number of visits made to web servers, the order of visits, the point of access, etc.

6. Blog behavior rules

GP PHARM, S.A. thanks you for your interest in making use of our participation channels for all users of this medium.

If you want to participate in our blogs, you will have to accept these rules:

1. User Responsibility. By participating in the blogs of the web you are the only responsible for the messages that you spread through those, guaranteeing GP PHARM, S.A. the total indemnity against any claim that could arise for such concepts. In case the messages contain material protected by intellectual or industrial property rights, the user guarantees that he/she is its owner or has the owner's authorization to spread it in the blogs and exempts GP PHARM, S.A. from any claim of third parties that may arise for such concepts.
2. The user must, before posting a message, choose the appropriate blog. Those messages that do not fit the theme of the blog may be deleted. It is strictly forbidden to publish promotions and links to commercial offers, advertising, promotional material, chain letters or any other direct or indirect promotional activity or any other type of comment that does not conform to the normal development of the themes of the blogs.
3. The user must respect the rest of the users. The user must be tolerant and respectful with the messages and opinions of other users. Messages that may be considered harmful to the rights of third parties or that attempt against the peaceful development of the blogs may be deleted.
4. GP PHARM, S.A. reserves the right to reproduce, modify, or disseminate the messages published in the blogs of the web according to the convenient terms and means without any type of compensation to the user.
5. GP PHARM, S.A. is not responsible for what is published in the web blogs, nor does it guarantee the truthfulness or accuracy of any information published therein. The sender of the messages or information is responsible for their content.
6. GP PHARM, S.A. does not guarantee the availability or continuity of the web blog service, and may modify, suspend or remove it from the web without prior notice at any time.
7. In the case that a user could be affected by illegal actions, or detects a bad use of the web blogs by other users, he/she can inform GP PHARM, S.A. through the e-mail rgpd@bcncorp.com, indicating in the subject reference “blog moderation”, so GP PHARM, S.A. can moderate or eliminate them.
8. The user will hold GP PHARM, S.A. harmless against any claim that could be presented for the messages that the user has spread in the blogs or for any other conduct related to or derived from the use by the user of the blogs of the web.

7. Applicable law and jurisdiction

Applicable law in case of dispute or conflict of interpretation of the terms that make up this Privacy Policy, as well as any matter related to the services of this website, will be Spanish law.