BioRep S.r.l. VAT number 03891970968, based in Via Olgettina, 60, 20132 Milan, constantly strives to protect the online privacy of users of its websites http://www.nativaprenatale.it and http://www.biorep.it (hereinafter, unless otherwise indicated, cumulatively the “Site”). This document (the “Policy”) has been drawn up in order to allow you to understand how your Personal Data, as defined below, will be treated when using the Site. The Policy is aimed at providing you with information necessary so that you can express explicit and informed consent to the processing carried out through the Site, if you deem it appropriate.
In general, any information or Personal Data that you will provide to BioRep Srl through the Site, or that is collected in another way through the Site, as part of the use of the services offered by BioRep Srl (the “Services”), as better defined in the following Paragraph 3, they will be treated according to the principles, internationally recognized, of lawfulness, correctness, transparency, purpose limitation and conservation, data minimization, accuracy, integrity and confidentiality.
- Data Controller and Data Protection Officer
- Personal data being processed
- Name, contact details and other Personal Data
- Job applications
- Special categories of personal data
- Data voluntarily provided by the subject
- Navigation data
- Purpose of the treatment
- Legal basis and mandatory or optional nature of the treatment
- Recipients of personal data
- Transfers of personal data
- Retention of personal data
- Rights of the interested party
1. Data Controller and Data Protection
OfficerBioRep S.r.l, as identified at the beginning of the Information, is the Data Controller for all Personal Data that are processed through the Site.You can contact the Data Protection Officer (“DPO”) of BioRep S.r.l at the following address: email@example.com
2. The personal data being processed
Following navigation of the Site, we inform you that BioRep Srl will process your Personal Data, which may be constituted – also depending on your decisions on how to use the Services – by an identification such as the name, an identification number, an online identification or one or more characteristic elements of your physical, physiological, psychic, economic, cultural or social identity suitable for making you identified or identifiable (hereinafter only “Personal Data”).
Your Personal Data may be collected both because you voluntarily provide it (e.g. when you request information from BioRep S.r.l through the Contact section on the site (https://www.biorep.it/contatti/ and http://nativaprenatale.it/contatti) or when you create your personal account in order to receive the Services offered by BioRep S.r.l) or simply by analyzing your behavior on the Site.
The Personal Data processed through the Site are as follows:
3. Name, contact details and other Personal Data
In various sections of the Site, in particular those relating to the creation of a personal account or to request information (“Contacts”), you will be asked to enter information such as your name, telephone number, email address, city of residence, the company you work for, etc.
Furthermore, when you communicate with BioRep S.r.l through the contacts you find on the Site (http://www.biorep.it/contatti), BioRep S.r.l will be able to collect the additional information you are deciding to provide.
4. Job applications
By registering in the section of the site relating to BioRep’s job applications at the address http://www.biorep.it/chi-siamo/lavora-con-noi (“Work with us”), you will be asked to fill in a form (the “Questionnaire”) through which you can provide BioRep S.r.l with different types of Personal Data, such as your contact details, professional / working details (e.g. university attended, knowledge of foreign languages, professional qualifications, links to your professional profiles on social networks, etc.) and to upload, through the specific function, your CV.
Upon receipt of an Application, BioRep Srl will be able to evaluate, even if you didn’t specified them in the Application, your professional profiles on social networks (eg Linkedin) or professional sites referable to you, if publicly accessible, for further information useful for evaluate your compatibility with the position you are applying for.
5. Special categories of personal data
Some sections of the Site (e.g. Work with us or Contacts) include free fields in which you can provide BioRep S.r.l with some information, which may contain Personal Data.Since these fields are arbitrary text, you could use them to communicate (voluntarily or not) some sensitive categories of Personal Data, such as data suitable to reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, trade unions membership, genetic data, biometric data intended to uniquely identify a natural person, data relating to health or sexual life or sexual orientation of the person.
BioRep S.r.l advices you not to send such Personal Data unless strictly necessary. Indeed, these special categories of Personal Data can be processed only with your explicit consent (manifested by the flag on the Application page) and in compliance with the pro tempore legislation in force. BioRep S.r.l therefore underlines the importance of expressing your explicit consent to the processing of special categories of Personal Data, if you decide to share this information.
With regard to the purpose (described below) of Pharmacovigilance, BioRep S.r.l will process the Personal Data which you will spontaneously send to the dedicated address only for the purpose described in Paragraph 3 of this Information.
6. Data voluntarily provided by the subject
As already mentioned above, in some sections of the Site (such as Work with us or Contacts) you are allowed to insert text messages, visible to BioRep S.r.l, which may contain other people’s personal data.
With respect to these hypotheses, you act as an independent data controller, assuming all the obligations and responsibilities of the law. In this sense, you confer on the point the widest indemnity with respect to any dispute, claim, request for compensation for damage from treatment, etc. that should reach BioRep S.r.l from third parties whose Personal Data have been processed through your use of the functions of the Site in violation of the rules on the protection of applicable personal data. In any case, if you provide or otherwise process Personal Data of third parties in the use of the Site, you guarantee from now – assuming any related responsibility – that this particular hypothesis of treatment is based on the consent of that interested third party or on another suitable legal basis that legitimizes the processing of the information in question.
7. Navigation data
During their normal operation, the IT systems and software procedures used to operate the Site acquire some Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, to identify anomalies and / or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site or third parties: except for this eventuality, at present the data on web contacts do not persist for more than seven days.
8. CookiesDefinitions, characteristics and application of the legislation
Cookies are small text files that sites visited by the user send and record on his computer or mobile device, to be then retransmitted to the same sites on the next visit. Thanks to cookies, a site remembers the user’s actions and preferences (such as, for example, login data, the chosen language, font sizes, other display settings, etc.) so that they do not have to be indicated when the user returns to visit this site or browse from one page to another. Cookies, therefore, are used to perform computer authentication, session monitoring and storage of information regarding the activities of users who access a site and may contain a unique identification code that allows you to keep track of the user’s navigation within of the site itself for statistical or advertising purposes. While browsing a site, the user can also receive cookies from sites or web servers other than the one he is visiting on his computer (so-called “third party” cookies).
There are various types of cookies, depending on their characteristics and functions, and these can remain on the user’s computer for different periods of time: so-called session cookie, which is automatically deleted when the browser is closed; the so called persistent cookies, which remain on the user’s equipment until a pre-established deadline.
For “profiling cookies”, on the other hand, i.e. those aimed at creating user profiles and used in order to send advertising messages in line with the preferences expressed by the same in the context of surfing the net, a prior consent is usually required of the user, although it depends on the applicable legislation.
Types of cookies used by the Site and possibility of (de-) selection
The Site uses the following cookies which can be de-selected, except for third-party cookies for which you will have to refer directly to the relative selection and de-selection methods of the respective cookies, indicated by means of links:
Technical navigation or session cookies, strictly necessary for the operation of the Site or to allow you to take advantage of the content and services requested.
Analytical cookies, which allow you to understand how the site is used. With these cookies, no information about your identity is collected, nor any Personal Data. The information is processed in an aggregate and anonymous form.
BioRep S.r.l also uses third-party cookies, i.e. cookies from sites or web servers other than that of BioRep S.r.l. It should be noted that these third parties, listed below with the related links to privacy policies, act as Data Processors for BioRep S.r.l (i.e. they process Personal Data on behalf of BioRep S.r.l).
As for third parties that send cookies through the Site, below are the links to their respective privacy policies:
Google Analytics (anonymized):
– Cookies on the Site
In detail, the cookies sent by BioRep S.r.l through the Site are indicated below:
|Type of proprietary cookie||Technical name of the cookies||Operation and purpose||Persistence time|
|Biorep||jsessionid||Allow the navigation of the Site and keep the user’s session valid while browsing it||Until the browser is closed|
You can block or delete (in whole or in part) technical and functional cookies through the specific functions of your browser. However, we inform you that not authorizing technical cookies could make it impossible to use the Site, view its contents and take advantage of the related services. Inhibiting functionality cookies may result in some services or certain functions of the Site being unavailable or not functioning properly and you may be forced to modify or manually enter some information or preferences each time you visit the Site.
The choices made with reference to the cookies of the Site will in turn be recorded in a special cookie. This cookie may, however, not work properly in some circumstances: in such cases, we advise you to delete unwanted cookies and to inhibit their use also through the functionality of your browsers.
Your preferences regarding cookies will have to be reset if you use different devices or browsers to access the site.
How to view and modify cookies through the browser
- Internet Explorer
You can also manage your choices regarding third-party cookies using online platforms such as AdChoice.
ATTENTION: disabling technical and / or functionality cookies the Site may not be available or some services or certain functions of the Site may not be available or may not function properly and you may be forced to modify or manually enter some information or preferences each time you visit the site.
9. Purpose of the treatment
BioRep S.r.l will use your Personal Data, collected through the Site, for the following purposes:
- provide the Services such as: allow you to register on the Site in order to access the display of documents with restricted access and help you, should you lose or forget the login / password details for registering on the Site; send you the newsletter of BioRep S.r.l that you requested as a service by registering and which contains only informative and non-commercial material; respond to your requests for information sent through the Contact section and provide you with any other Service you request (“Provision of the Service”);
- the adequate implementation of activities connected and instrumental to the purposes of the Pharmacovigilance to which BioRep S.r.l is required by law, such as, for example: (i) identification of any unknown adverse reactions; (ii) improvement and enhancement of information on suspected adverse reactions already known; (iii) assessment of the causal link between drug administration and the observed adverse reaction; (iv) notification to the competent authority of this information to ensure that the drugs used have a favorable benefit / risk ratio for the population (“Pharmacovigilance”);
- examine the Candidates’ Questions and contact those who sent Questions through the Site (“Recruitment”);
- send you marketing communications, promotions and advertisements, market research and surveys, by e-mail, SMS, paper mail, by phone, by banner, instant messaging, by an operator, through the official social media pages of BioRep S.r.l, (” Marketing”);
- to create your profile by collecting and analyzing information about your general activities on the Site. This profile will be used to provide you with information on other products and / or services that BioRep S.r.l believes may interest you and to show you advertisements that may be relevant to your tastes. All the algorithms involved in this automated or semi-automated process are regularly tested to ensure that you are not offered products that do not interest you (“Profiling”);
- fulfill legal obligations that require BioRep S.r.l to collect and / or further process certain types of Personal Data (“Compliance”);
prevent or detect any abuse in the use of the Site, or any fraudulent activity and therefore allow BioRep S.r.l to protect itself in court (“Abuse / Fraud”).
10. Legal basis and mandatory or optional nature of the treatment
The legal bases used by BioRep S.r.l to process your Data, according to the purposes indicated in the previous Paragraph 3, are as follows:
Service provision: processing for this purpose is necessary in order to provide you with the Services and, therefore, for the execution of the contract with you. It is not mandatory to provide BioRep S.r.l with your Personal Data for this purpose, but otherwise it will not be possible to provide you with any Service. The same applies to the newsletter service that arises from your specific request by entering an e-mail address and which you can revoke at any time by following the instructions in Paragraph 8 of this information.
Pharmacovigilance: in this case data processing is needed in order to be able to carry out what is required by the legislation on Pharmacovigilance, mandatory for the company. The provision of data is on voluntary basis, but failure to provide data could jeopardize the correct functioning of the pharmacovigilance system. In case of reports, data collected for this purpose will be processed exclusively for the aforementioned purposes.
Recruitment: in this case data processing is used by BioRep S.r.l to be able to take your application into consideration and, therefore, it is necessary to be able to start the selection process in order to offer you, possibly, a job position. It is not mandatory to provide BioRep S.r.l with your Personal Data for this purpose, but otherwise it will not be possible to take your Application into consideration. If you wish to provide special categories of Personal Data (e.g. data relating to health, religion, etc.), BioRep S.r.l will need your specific consent which you can give at the bottom of the Application.
Marketing: in this case data processing is based on your consent. It is not mandatory to give your consent to BioRep S.r.l for this purpose and you are free to withdraw it at any time without any consequence (except for the fact that you will no longer receive marketing communications from BioRep S.r.l). You can revoke your consent previously given by following the indications in Paragraph 8 of this Policy.
Profiling: in this case data processing is based on your consent. It is not mandatory to give your consent to BioRep S.r.l for this purpose and you are free to withdraw it at any time without any consequence. You can revoke your consent previously given by following the indications in Paragraph 8 of this Policy.
Compliance: in this case data processing is necessary for BioRep S.r.l in order to fulfill any legal obligations. When you provide Personal Data to BioRep S.r.l, they must be processed according to the applicable legislation, which could result in their conservation and communication to the Authorities for accounting, tax or other obligations.
Abuse / Fraud: the information collected for this purpose will be used exclusively to prevent and / or identify any fraudulent activity or abuse in the use of the Site and therefore allows BioRep S.r.l to protect itself in court.
11. Recipients of personal data
Your Personal Data may be shared with the following subjects listed below (the “Recipients”):
- subjects who typically act as data processors, that is: i) people, companies or professional firms that provide assistance and advice to BioRep S.r.l in accounting, administrative, legal, tax, financial and credit recovery matters relating to the provision of the Services ;
- subjects with whom it is necessary to interact for the provision of the Services (for example, hosting providers or suppliers of platforms for sending emails);
- subjects delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communication networks);
- persons authorized by BioRep S.r.l to process Personal Data necessary to carry out activities strictly related to the provision of the Services, who have committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees of BioRep S.r.l);
- companies of SAPIO S.r.l Group for internal administrative purposes;
- subjects, entities or authorities to whom it is mandatory to communicate your Personal Data for Compliance, Abuse or Fraud purposes, or for orders from the authorities;
- for the purpose of Pharmacovigilance to subjects who access the National Pharmacovigilance Network, to subjects obliged to carry out pharmacovigilance activities (AIFA, holders of the marketing authorization for medicines, Italian Regions, Local Health Units, Pharmacovigilance Office of hospitals or Scientific Research and Treatment Institutes), to other companies of the SAPIO S.r.l Group, to pharmacovigilance consultancy companies as well as to subjects to whom the right to access personal data is recognized by law and / or regulations secondary or public authority orders.
12. Transfers of personal data
BioRep S.r.l. can transfer your data outside the European Economic Area.
13. Retention of Personal Data
The Personal Data processed for the purpose of Providing the Services will be kept by BioRep S.r.l for the time strictly necessary for the aforementioned purpose (e.g. to respond to requests for information sent to us through the Contacts section). In any case, since these Personal Data are processed to provide you with the Services, BioRep S.r.l may keep them for a longer period, in particular for what may be necessary in order to protect the interests of BioRep S.r.l from possible complaints relating to the Services.
Personal Data processed for the purpose of Pharmacovigilance will be kept for the period necessary for the aforementioned purpose, in accordance with current regulations. Specifically, the Personal Data will be made anonymous within three months of the closure of the case and in any case no later than two years from the end of the year in which the first report took place.
Personal Data processed for the purpose of Recruitment will be kept by BioRep Srl for the entire period in which the position for which the Application was sent or, if shorter, for two (2) years BioRep Srl reserves the right to contact candidates before the expiry of this period to request them to extend the retention period of their Personal Data or to request an update of the Application. In case of no response, BioRep S.r.l deletes the Personal Data collected.
Personal Data processed for Marketing and Profiling purposes will be kept by BioRep S.r.l until the moment you withdraw your consent; however, you will be asked to renew your consent periodically. Once consent has been withdrawn, BioRep S.r.l will no longer use your Personal Data for these purposes, but may still retain it, in particular for what may be necessary in order to protect BioRep S.r.l’s interests from possible complaints based on such treatments.
Personal Data processed for Compliance purposes will be kept by BioRep S.r.l for the period provided for by specific legal obligations or by applicable legislation.
The Personal Data processed in order to prevent Abuse / Fraud will be kept by BioRep S.r.l for the time strictly necessary for the aforementioned purpose and therefore until the moment when BioRep S.r.l will be required to keep it in order to protect itself in court to communicate said data to the competent Authorities.
14. Rights of the interested party
You have the right to ask BioRep S.r.l, at any time:
- access to your Personal Data, (or a copy of such Personal Data), as well as further information on the treatments underway on them;
- the correction or updating of your Personal Data processed by BioRep S.r.l, if they are incomplete or out of date;
- the cancellation of your Personal Data from the BioRep S.r.l databases;
- the limitation of the processing of your Personal Data by BioRep S.r.l;
- to obtain the Personal Data concerning you in a structured, commonly used and machine-readable format;
as well as you can:
- object to the processing of your Personal Data by BioRep S.r.l;
- withdraw your consent for Marketing purposes.
You can revoke the consent to Marketing sent by e-mail using the appropriate link at the bottom of each e-mail received. The same method can be used to stop receiving the BioRep S.r.l newsletter, if I have requested it as a Service.
In addition to the above, you can also exercise your rights by writing to BioRep S.r.l at the following address: firstname.lastname@example.org.
In any case, you always have the right to lodge a complaint with the competent Control Authority (Guarantor for the Protection of Personal Data) if you believe that the processing of your Personal Data is contrary to the legislation in force.