PHARMAPRENEURS PRIVACY POLICY

1. INTRODUCTION

1.1 PHARMAPRENEURS is a proudly South African commercialisation-focused company. We are a highly experienced small-to-medium-sized pharmaceutical outsourcing solutions business, with an agile infrastructure that supports the strategic intent of our business partners in healthcare

1.2 PHARMAPRENEURS virtual business model and the dynamic team that back it up provides consulting, advisory, business-to-business and workplace solutions in commercialisation, business development, market access, patient support programs and medical affairs. We have adopted an entrepreneurial, skilled and agile approach to ensure that we proactively innovate, connect and collaborate to drive progress and deliver change for the benefit of our business partners, customers and patients.

1.3 As part of managing the business and creating value for its various stakeholders, PHARMAPRENEURS is required, in certain instances, to process personal information. Accordingly, PHARMAPRENEURS is required to protect the personal information as set out in the Protection of Personal Information Act 4 of 2013, including its Regulations (POPI Act).

1.4 This notice constitutes PHARMAPRENEURS policy statement to declare its commitment to comply with the POPI Act. Accordingly, it provides insights on how PHARMAPRENEURS processes personal information of data subjects as set out in the POPI Act.

1.5 PHARMAPRENEURS shall ensure that personal information is processed within the parameters of the law.

1.6 This notice must be read in conjunction with the POPI Act and its Regulations, where applicable.

2. OBJECTIVE

2.1 The objective of this notice is to give effect to the POPI Act and to provide clarity on the following:

2.1.1 What personal information PHARMAPRENEURS collects about a data subject and the basis thereof;

2.1.2 How PHARMAPRENEURS uses and protects the personal information of a data subject;

2.1.3 How long PHARMAPRENEURS keeps the personal information of a data subject;

2.1.4 The rights of a data subject regarding their personal information; and

2.1.5 What the data subject should do if she does not want to provide PHARMAPRENEURS with personal information

3. INTERPRETATION AND DEFINITIONS

In this notice:
3.1 Clause headings are for convenience and reference only and shall not be used in the interpretation thereof;

3.2 Words describing any one gender shall include any other gender

3.3 Words describing the singular shall include the plural and vice versa

3.4 All the annexures (if any) hereto are incorporated herein and shall have the same force and effect as if they were set out in the body of this notice;

3.5 The following words and/or expressions shall, unless the context indicates otherwise, bear the meaning assigned to them below and in the POPI Act;

3.5.1 “Cookie/s” (also called web cookie, Internet cookie, browser cookie, or simply cookie) is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing to inter alia remember stateful information (such as items added in the shopping cart in an online store) or to record the user’s browsing activity.

3.5.2 “Data subject” means the person to whom Personal information relates;

3.5.3 “Employee” means a permanent, fixed-term or temporary employee of PHARMAPRENEURS

3.5.4 “Operator” means a third party that processes Personal information in terms of a mandate or contract with PHARMAPRENEURS, without coming under the direct authority of PHARMAPRENEURS;

3.5.5 “Information officer” means the person appointed by PHARMAPRENEURS, from time to time, who is responsible for the monitoring of compliance, with the conditions for the lawful processing of Personal information; dealing with requests made to PHARMAPRENEURS in terms of the POPI Act; working with the Regulator in relation to investigations conducted in relation to prior authorisation by the Data subject and ensuring compliance by PHARMAPRENEURS with the provisions of the POPI Act;

3.5.6 “Person” means any person, company, close corporation, trust, partnership or other entity;

3.5.7 “Personal information” means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to—

3.5.7.1 information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;

3.5.7.2 information relating to the educational, medical, financial, criminal or employment history of the person;

3.5.7.3 any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;

3.5.7.4 the biometric information of the person;

3.5.7.5 the personal opinions, views or preferences of the person;

3.5.7.6 correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;

3.5.7.7 the views or opinions of another individual about the person; and

3.5.7.8 the name of the person if it appears with other Personal information relating to the person or if the disclosure of the name itself would reveal information about the person;

3.5.8 “Privacy Notice or Notice” means this Notice as amended from time to time;

3.5.9 “Processing” means any operation or activity or any set of operations, whether or not by automatic means, concerning Personal information, including—

3.5.9.1 the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation, or use;

3.5.9.2 dissemination by means of transmission, distribution or making available in any other form; or

3.5.9.3 merging, linking, as well as restriction, degradation, erasure or destruction of information.

4. PROCESSING OF PERSONAL INFORMATION

4.1 Personal information PHARMAPRENEURS collects about a data subject and the basis thereof

The personal information PHARMAPRENEURS collects in the ordinary course of business includes:

a. only information that is adequate, necessary, and relevant to enable it to effectively render a service or assist in any manner required, such as the Data subject’s name, identity number (where applicable), registration number, Data subject’s employees or its director’s Personal information, contact information etc;

b. electronic communications sent to PHARMAPRENEURS;

c. information submitted to PHARMAPRENEURS in response to a vacancy advertisement;

d. technical information, for instance through the use of cookies, such as activity data, such as when the Data subject completes a form on the PHARMAPRENEURS website


e. personal information that PHARMAPRENEURS collects when it monitors other websites may include the Data subject’s public Personal information, for example when PHARMAPRENEURS monitors digital conversations on public platforms to understand what people are saying about it or the pharmaceutical industry in general. PHARMAPRENEURS may combine information that it has about a Data subject from various sources; and

f. the PHARMAPRENEURS website uses various technologies including “cookies” which allow the website to recognise and respond to the Data subject as an individual. The Data subject can elect to accept or decline cookies. If a Data subject elects to decline cookies, not all elements of the website may function as intended, so website experience may be affected.

4.2 Protecting the Data subject’s Personal information

a. PHARMAPRENEURS uses a variety of security measures and technologies to help protect Personal information of a Data subject from unauthorised access, use, disclosure, alteration, or destruction in line with applicable Personal information protection and privacy laws. For example, when PHARMAPRENEURS shares the Personal information of a Data subject with external suppliers, it shall put in place a written agreement which commits the suppliers to keep the Data subject’s Personal information confidential, and to put in place appropriate security measures to keep it secure.
b. the transmission to PHARMAPRENEURS of information via the internet or a mobile phone network connection may not be completely secure and any transmission is at the Data subject’s risk.
c. despite the security measures that PHARMAPRENEURS has in place to protect Personal information of a Data subject (firewalls, password access and encryption methods), the Data subject acknowledges that it may be accessed by an unauthorised third party, e.g. as a result of an illegal activity.
d. from time to time PHARMAPRENEURS may provide links to websites or mobile applications that it does not own or control. This Notice does not apply to those websites. If a Data subject chooses to use those websites, she must check the legal and privacy policies or statements posted on each website or mobile application he accesses to understand their privacy practices.


How does PHARMAPRENEURS use the Personal information of a Data subject

PHARMAPRENEURS may use the Personal information of a Data subject to provide the Data subject with information and services including:

a. job postings

b. for consulting and advisory services provided by PHARMAPRENEURS

c. contact and interact with the Data subject, including to:

i. respond to requests from the Data subject (for instance in case the Data subject applied for employment); and

ii. provide important notices and updates, such as changes to terms, standard operating procedures (SOPs), policies, security alerts and administrative messages.

d. operate PHARMAPRENEURS business, including:


i. complying with applicable laws, regulations and guidance; and

ii. complying with demands or requests made by regulators, governments, courts and law enforcement authorities.

e. Improve PHARMAPRENEURS day-to-day operations, including:

i. for internal purposes such as auditing, data analysis and research to help PHARMAPRENEURS deliver content and services;


ii. to improve PHARMAPRENEURS services and communications to the Data subject; and

iii. to ensure that PHARMAPRENEURS has up-to-date contact information for the Data subject, where applicable.

f. To contact you by email, telephone call, SMS, or other equivalent forms of electronic communication, such as mobile application’s push notifactions regarding updates or informative communications related to the functionalities, products or contracted services, including security updates, when necessary or reasonable for their implementation.

4.3 How long will PHARMAPRENEURS keep Personal information of a Data subject

PHARMAPRENEURS will always keep the Personal information of a Data subject for the period required by law and where it needs to do so in connection with legal action or an investigation in which it is involved. Otherwise, PHARMAPRENEURS will keep Personal information of a Data subject:

g. for as long as needed to provide the Data subject with access to services requested;

h. where the Data subject has contacted PHARMAPRENEURS with a question or request, for as long as necessary to allow PHARMAPRENEURS to respond to the question or request and as required by law.


4.4 Instances where sharing of Personal information of a Data subject by PHARMAPRENEURS is permitted

a. PHARMAPRENEURS may share Personal information of a Data subject with the following third parties:

i. PHARMAPRENEURS agents and suppliers, including those who provide it with technology services such as data analytics, hosting and technical support;

ii. PHARMAPRENEURS professional advisors, auditors and business partners;

iii. regulators, governments and law enforcement authorities; and

iv. other third parties in connection with re-organising all or any part of PHARMAPRENEURS business.


4.5 The Data subject’s rights regarding Personal information

The Data subject is entitled to:

a. request PHARMAPRENEURS for access to Personal information PHARMAPRENEURS holds;

b. request the correction and/or deletion of Personal information;

c. request the restriction of the processing of her Personal information, or object to that processing;

d. withdraw consent to the processing of Personal information (where PHARMAPRENEURS is processing Personal information based on consent);

e. withdraw her consent to receive marketing messages;


f. complain to local data protection authority if privacy rights are violated, or if she has suffered as a result of unlawful processing of Personal information.

4.6 What the Data subject should do if she does not want to provide PHARMAPRENEURS with Personal information

4.6.1 where a Data subject is given the option to share Personal information with PHARMAPRENEURS, she can always elect not to do so.

4.6.2 if a Data subject objects to the processing of Personal information, or if she has provided consent to processing and later choose to withdraw it, PHARMAPRENEURS will comply with the request in accordance with its legal obligations. PHARMAPRENEURS legal obligations in respect of the withdrawn information shall therefore cease to exist.

5. IMPORTANT NOTICE TO DATA SUBJECTS

5.1 By visiting PHARMAPRENEURS website and communicating electronically with PHARMAPRENEURS, the Data subject consents to the processing, including transfer of Personal information as set out in this Notice.


6. CONTACT US

6.1 For any questions or requests regarding this Notice or if a Data subject would like to exercise her rights please use the following contact information of the Information Officer:

Shaista Lowton
072 776-7862 or email information@pharmapreneurs.co.za