Who are we?
For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR), Vivian Corporation is the ‘controller’ of Data subject data. Our registered address is The Hub, Troubridge Street, Marsa, MRS1113.
Vivian Corporation is a leading marketing and distribution company involved in Healthcare and fast moving consumer goods (FMCG). If you have any queries about this Policy, the way in which we process personal data, or about exercising any of your rights, you may contact our Privacy Officer by sending an email to firstname.lastname@example.org or writing to Privacy Officer, Address: The Hub, Troubridge Street, Marsa, MRS1113.
What personal data do we collect?
We may collect and process the following personal data: Information you provide to us:
- A data subject may give information by filling up a form, calling in the office, give in information to buy a product/service, warranty etc.
We may collect your name, e-mail address, postal address, telephone number, ID card number, gender and Date of Birth and other relevant information for legitimate business purposes.
Information we collect about you
If you visit our Website, we may automatically collect the following information:
- technical information, including the internet protocol (IP) address used to connect your computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit to our Website such as the products and/or services you searched for and view, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Information we receive from other sources
We may receive personal data information from contracted third parties.
Ex: customer surveys, server providers, information readily available online
Information about other people
If you provide information to us about any person other than yourself or children under your legal guardianship, such as your relatives, next of kin, your advisers or your suppliers, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.
Medical information, Product complaints and Drug Safety
If you provide information to our Medical Representatives or our Regulatory Affairs and Quality Department related to a Product Complaint or Drug Safety, and when you contact us by phone, email, fax or postal mail to place an enquiry about a product or raise a complaint related to a product or report an adverse event related to a medicinal product, your personal data will be processed.
When you call us by phone, we will request Personal Data during your call as outlined below.
If you are a healthcare professional:
- Name and contact information (telephone number, email address)
- Information related to your profession.
- Information to your use of our product.
If you are not a health professional:
- Name and contact information (telephone number, email address)
- Information to your use of our product
- If reporting an adverse event, we may also request your gender, race and date of birth.
Please do not provide us with information relating to another identifiable person (e.g. your patient or relative). For example, if you report an adverse event for your patient or a relative, do not provide us with the patient’s or relative’s name or address. If you provide any information relating to an identifiable person, you are telling us that you have the authority to share that information and to permit us to use the information as described in this Privacy Notice.
How do we use your personal data?
When we ask you to supply us with personal data we will make it clear whether the personal data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any personal data we ask for is optional.
Contract performance: we may use your personal data to fulfil a contract, or take steps linked to a contract:
- to provide the products and/or services to you
- to communicate with you in relation to the provision of the contracted products and services
- to provide you with administrative support such as account creation, security, and responding to issues; and
- provide you with industry information, surveys, information about our awards and events, offers and promotions, related to the products and/or services.
Legitimate interests: where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests are:
- providing you with newsletters, surveys, information about our events, offers, and promotions, related to products and services offered by Vivian Corporation which may be of interest to you;
- communicating with you in relation to any issues, complaints, or disputes;
- improving the quality of experience when you interact with our products and/or services, including testing the performance and customer experience of our website;
- performing analytics on sales/marketing data, determining the effectiveness of promotional campaigns.
NOTE: you have the right to object to the processing of your personal data on the basis of legitimate interests as set out below, under the heading Your rights.
Consent: where you have given your express consent to receive marketing communications, we may use your personal data to:
- send you newsletters, surveys, information about products and events, offers, and promotions, related to products and services offered by Vivian Corporation which may be of interest to you;
- Developing, improving, and delivering marketing and advertising for products and services offered by a Vivian Corporation.
Where required by law: we may also process your personal data if required by law, including responding to requests by government or law enforcement authorities, or for the prevention of crime or fraud.
In the case of the reporting of adverse events and product complaints, we use personal data to comply with our legal and regulatory obligations. In view of this, you may be contacted if we require further information about the adverse event or complaint that you have reported.
Who do we share your personal data with?
We may share your personal data with subcontracted entities. You can read more about our company at www.viviancorp.com
We take all reasonable steps to ensure that our staff protect your personal data and are aware of their information security obligations. We limit access to your personal data to those who have a genuine business need to know it.
We may also share your personal data with trusted third parties including:
- legal and other professional advisers, consultants, and professional experts;
- service providers contracted to us in connection with provision of the products and services such as providers of IT services and customer relationship management services; and
- analytics and search engine providers that assist us in the improvement and optimization of our Website.
We will ensure there is a contract in place with the categories of recipients listed above which include obligations in relation to the confidentiality, security, and lawful processing of any personal data shared with them.
Where a third-party recipient is located outside the European Economic Area, we will ensure that the transfer of personal data will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission where the data protection authority does not believe that the third country has adequate data protection laws.
We will share personal data with law enforcement or other authorities if required by applicable law.
How long will you keep your personal data?
Where there is a contract between us, we will retain your personal data for a period no longer than is necessary (link to opt out to retention policy).
Where do we store your personal data and how is it protected?
We take reasonable steps to protect your personal data from loss or destruction. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorized access.
Under the GDPR, you have various rights with respect to our use of your personal data:
Right to Access
You have the right to request a copy of the personal data that we hold about you by contacting us at the email or postal address given below. Please include with your request information that will enable us to verify your identity. We will respond within 30 days of your request. Please note that there are exceptions to this right. We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information. Or if your request is manifestly unfounded or excessive.
Right to rectification
We aim to keep your personal data accurate and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.
Right to erasure
You have the right to request the deletion of your personal data where, for example, the personal data are no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed. If you would like to request that your personal data is erased, please contact us using the contact details provided below.
Right to object
In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data, or if your data is being processed for direct marketing purposes. If you would like to object to the processing of your personal data, please contact us using the contact details provided below.
Right to restrict processing
In certain circumstances, you have the right to request that we restrict the further processing of your personal data. This right arises where, for example, you have contested the accuracy of the personal data we hold about you and we are verifying the information, you have objected to processing based on legitimate interests and we are considering whether there are any overriding legitimate interests, or the processing is unlawful and you elect that processing is restricted rather than deleted. Please contact us using the contact details provided below.
Right to data portability
In certain circumstances, you have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format. This right arises where you have provided your personal data to us, the processing is based on consent or the performance of a contract, and processing is carried out by automated means. If you would like to request that your personal data is ported to you, please contact us using the contact details provided below.
Please note that the GDPR sets out exceptions to these rights. If we are unable to comply with your request due to an exception we will explain this to you in our response.
You may unsubscribe from marketing communications at any time by contacting us at email@example.com or by using the ‘unsubscribe’ functionality on the footer of any marketing communications sent to you.
If you have any queries about this Policy, the way in which we process personal data, or about exercising any of your rights, you may contact our Privacy Officer by sending an email to firstname.lastname@example.org or writing to Privacy Officer, Vivian Corporation, The Hub, Troubridge Street, Marsa, MRS1113.
If you believe that your data protection rights may have been breached, and we have been unable to resolve your concern, you may lodge a complaint to the applicable supervisory authority or to seek a remedy through the courts. Please visit www.idpc.org.mt for more information on how to report a concern to the Commissioner’s Office.
Changes to our Policy
Any changes we may make to our Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Policy.
Data and records shall be kept for a minimum of 10 years. All personal data shall be immediately deleted once the data subject asks for their data to be withdrawn.