Data Security
The respect of privacy is a serious concern to which we pay special attention when
processing and using personal data. We therefore attribute great importance to the
protection of your personal data. Insofar as personal data is collected (e.g. your
name, address or other contact details), it is processed and used exclusively in
accordance with applicable data protection regulations.
In the following we would like to inform you about the processing of personal data
when using this website. Personal data are all data that identify you, e.g. name,
address, e-mail addresses, user behavior.

1. Controller & Data Protection coordinator
Responsible Controller for the collection, processing and use of your personal data
in the context oft he GDPR is: Specific Pharma a/s
Borgmester Christiansens Gade 40, 1790 København V.
Telephone +45 36454536
You can reach our data protection coordinator at gdpr@nomeco.dk or our postal
address with the addition “the data protection coordinator”.

2. Data Collection during the visit of the website
(1) When using the website for information purposes only, i.e. if you do not register
or otherwise provide us with information, we only collect the personal data that your
browser transmits to our server. If you wish to view our website, we collect the
following data, which is technically necessary for us to display our website to you
and to ensure its stability

• IP address
• date and time of the request
• Time zone difference to Greenwich Mean Time (GMT)
• Content of the request (specific page)
• Access status/HTTP status code
• amount of transferred data
• Referrer URL
• Browser Type
• Operating system and its interface
• Language and version of the browser software
(2) In addition to the aforementioned data, cookies are stored on your computer
when you use our website. Cookies are small text files that are stored on your hard
disk in the browser you use and through which certain information flows to the
instituion that sets the cookie. Cookies cannot run programs or transmit viruses to
your computer. They serve to make the Internet offer more user-friendly and effective
overall.
(3) Use of cookies:
a) This website uses the following types of cookies, the scope and functioning of
which are explained below:
• Transient cookies (see b)
• Persistent cookies (see c).
b) Transient cookies are automatically deleted when you close your browser. This
includes in particular the session cookies. These store a so-called session ID, with
which different requests of your browser can be assigned to the common session.

This will allow your computer to be recognized when you return to our website.
Session cookies are deleted when you log out or close your browser.
c) Persistent cookies are automatically deleted after a specified period, which may
vary depending on the cookie. You can delete cookies at any time in the security
settings of your browser.
d) You can configure your browser settings according to your wishes and, for
example, refuse the acceptance of third party cookies or all cookies. Please note that
you may not be able to use all functions of this website.
e)We use cookies to identify you for follow-up visits if you have an account with us.
Otherwise you would have to log in again for each visit.
f)[The Flash cookies used are not collected by your browser, but by your Flash plug-
in. We also use HTML5 storage objects that are stored on your mobile device. These
objects store the required data independently of your browser and do not have an
automatic expiry date. If you do not wish the Flash cookies to be processed, you
must install an appropriate add-on, e.g. “Better Privacy” for Mozilla Firefox (https://
addons.mozilla.org/de/firefox/addon/betterprivacy/) or the Adobe Flash killer cookie
for Google Chrome. You can prevent the use of HTML5 storage objects by using
private mode in your browser. We also recommend that you regularly delete your
cookies and browser history manually.
(3) Of course, you can also view our website without cookies. Internet browsers are
regularly set to accept cookies. In general, you can deactivate the use of cookies at
any time via the settings of your browser. Please use the help functions of your
Internet browser to find out how you can change these settings. Please note that
some features of our website may not work properly or at all if you have disabled the
use of cookies.
(4) The legal basis for data processing in accordance with the above paragraphs is
Art 6 (1) lit. f) GDPR. Our interests in data processing are in particular to enable the
use of the website by ensuring the stability of its operation and the security of the
website. Unless specifically stated, we only store personal data for as long as is
necessary to fulfil the purposes pursued.
(5) If we make use of contracted service providers for individual functions of our offer
or would like to use your data for advertising purposes, we will inform you in detail
about the respective processes below. We also specify the defined criteria for the
storage period.

3. E-Mail Contact
If you contact us (e.g. via contact form or e-mail), we store your details for
processing the enquiry and for any follow-up questions. We delete the data arising in
this context after the storage is no longer necessary, or limit the processing if
statutory retention obligations exist. We only store and use further personal data if
you give your consent or if this is legally permissible without special consent.

4. Usage of our Portal
(1) If you wish to use our portal, you must register by entering your e-mail address, a
password of your choice and your freely definable user name. There is no obligation
to provide a clear name, pseudonymous use is possible. We use the so-called
double opt-in procedure for registration, i.e. your registration is not complete until you
have previously confirmed your registration via a confirmation e-mail sent to you for
this purpose by clicking on the link contained therein. If your confirmation is not
received within [24 hours], your registration will be automatically deleted from our
database. It is obligatory to provide the aforementioned data; all further information
can be provided voluntarily by using our portal.
(2) If you use our portal, we store your data necessary for the fulfilment of the
contract, including information on the method of payment, until you finally delete your
access. Furthermore, we store the voluntary data provided by you for the duration of
your use of the portal, unless you delete it beforehand. You can manage and change
all information in the protected customer area. The legal basis is Art. 6 (1) lit. b and
lit. f GDPR.
(3) In order to prevent unauthorized access to your personal data, especially
financial data, the connection is encrypted using TLS technology.
5.Newsletter
(1) By actively giving your consent you can subscribe to our newsletters, with which
we inform you about our current interesting events and services.
(2) We use the double opt-in procedure to subscribe to our newsletter. This means
that after your registration we will send you an e-mail to the specified e-mail address
in which we ask you to confirm that you would like the newsletter to be sent. If you
do not confirm your registration within 24 hours, your information will be blocked and
automatically deleted after one month. In addition, we store your IP addresses and
the time of registration and confirmation. The purpose of the procedure is to be able
to prove your registration and, if necessary, to clarify a possible misuse of your
personal data.
(3) The only mandatory information for sending the newsletter is your e-mail
address. The indication of further, separately marked data is voluntary and is used to
be able to address you personally]. After your confirmation we will save your e-mail
address for the purpose of sending you the newsletter. The legal basis is Art. 6 (1) lit.
a GDPR.
(4) You can revoke your consent to the sending of the newsletter at any time and
cancel the newsletter. You can declare your revocation by clicking on the link
provided in every newsletter e-mail, or by sending a message to the contact details
stated in the imprint.
5 Further functions and offers of our website
(1) In addition to the purely informational use of our website, we offer various
services, possibly at the owner’s expens, which you can use if interested. Usually,
you must provide further personal data, which we use to provide the respective
service and to which the aforementioned data processing principles apply. For the
provision of chargeable services, we ask for additional data, e.g. payment details, in
order to be able to execute your order. We store this data in our systems until the
legal retention periods have expired.
(2) In some cases, we use external service providers/contract processors to process
your data. These have been carefully selected and commissioned by us, are bound
by our instructions and are regularly checked.
(3) Furthermore, we may pass on your personal data to third parties if we offer
participation in promotions, competitions, conclusion of contracts or similar services
together with partners. You will receive more detailed information when you provide
your personal data.
(4) If our service providers or partners are based in a country outside the European
Economic Area (EEA), we will inform you of the consequences of this circumstance
in the description of the offer.

6. Plugins
Google Analytics
a) The website uses Google Analytics, a web analytics service provided by Google,
LLC. (“Google”). Google Analytics also uses cookies, i.e. text files that are stored on
your computer and allow an analysis of your use of the website. The information
generated by the cookie about your use of this website is usually transferred to a
Google server in the U.S.A. and stored there. Through the activation of IP
anonymization on the website, however, your IP address will be truncated by Google
within Member States of the European Union or other parties to the Agreement on
the European Economic Area. Only in exceptional cases is the complete IP address
transmitted to a Google server in the U.S.A. and truncated there.
b) On behalf of us Google will use this information for the purpose of analyzing your
use of the website, compiling reports on website activity and providing us with other
services relating to website activity and internet usage.
c) Google will not associate the IP address transmitted by your browser with any
other data held by Google. Google may also transfer this information to third parties
where required to do so by law, or where such third parties process this information
on Google’s behalf.
d) At any time you may delete cookies placed on your computer by calling up the
relevant menu item in your internet browser or deleting the cookies on your hard
drive. For details, see the Help menu of your internet browser.
e) You may refuse the use of cookies by selecting the appropriate settings on your
browser; we advises, however, that if you do this you may not be able to use the full
functionality of this website. You can also prevent the data generated by the cookie
about your use of the website (incl. your IP address) being sent to Google as well as
the processing of this data by Google by downloading and installing the browser
plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en
f) Further information is available at http://tools.google.com/dlpage/gaoptout?hl=en.
Google Maps
This website uses Google Maps API to display geographical information visually.
When using Google Maps, Google also collects, processes and uses data about the
use of map functions by visitors. You can find more information about Google’s data
processing in the Google Privacy Policy. There you can also change your personal
data protection settings in the Data Protection Center.
Google Web Fonts
Google Fonts are used to improve the visual presentation of various information on
this website. The web fonts are transferred to the cache of the browser when the
page is called up so that they can be used for display. If your browser does not
support Google Web Fonts or does not allow access, the text will be displayed in a
default font.
Data submitted in connection with the page visit is sent to resource-specific domains
such as fonts.googleapis.com or fonts.gstatic.com. They are not associated with
data that may be collected or used in connection with the parallel use of
authenticated Google services.
You can set your browser so that the fonts are not loaded from Google servers (e.g.
by installing add-ons like NoScript or Ghostery for Firefox.) If your browser does not
support Google Fonts or if you block access to the Google servers, the text will be
displayed in the system’s default font.

Social Plugins
On our website social plugins (“plugins”) are used by social networks.
In order to increase the protection of your data when visiting our website, the plugins
are not unrestricted, but only integrated into the page using an HTML link (so-called
“Shariff solution” from c’t). This integration ensures that no connection is established
with the servers of the provider of the respective social network when a page of our
website containing such plug-ins is called up. Click on one of the buttons, a new
window of your browser opens and calls up the page of the respective service
provider, on which you can (if necessary after entering your login data) e.g. press the
Share button.
The purpose and scope of data collection and the further processing and use of the
data by the providers on their pages as well as your relevant rights and setting
options for the protection of your privacy can be found in the data protection
information of the following providers:
LinkedIn Corporation (2029 Stierlin Court – Mountain View – CA 94043 – USA)
facebook Inc. (1601 p. California Ave, Palo Alto, CA 94304, USA)
Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043 USA)

7. Your Data Privacy Rights
We gladly want to you inform you regarding your rights according to the general data
protection regulation:
Right of Access
You have the right to request confirmation whether data concerning you are being
processed and to request information regarding these data according to Art. 15
GDPR
Right to rectification
In accordance with Article 16 of the GDPR, you have the right to request the
completion or correction of inaccurate data concerning you.
Right to erasure
In accordance with Art. 17 GDPR, you have the right to demand that relevant data
may be deleted in case there are no legal obligations preventing the deletion.
Right to restriction of processing
You may demand a restriction of the processing in accordance with Art. 18
Right of data portability
You have the right to request to receive the data provided to us in accordance with
Art. 20 GDPR and additionally to request its transmission to other processors
Right to object
You may object to the future processing according to Art. 21 GDPR at any time.
Right to revocation
You have the right to revoke consent anytime according to Art. 7 Par. 3 GDPR valid
for the future.
Right to notify the supervisory authority
In accordance with Art. 77 GDPR you have the right to file a complaint with the
competent supervisory authority.

8. Reporting System
The PHOENIX group, i.e. the PHOENIX Pharmahandel GmbH & Co KG as well as
its affiliated companies according to §§ 15ff AktG, has established a web based
reporting system which is designed to enable employees, business partners,
customers and third parties an easy system by which to report data incidents or
concerns. These reports are taken seriously and are reviewed and actioned regularly
and are used to improve the protection of personal data.
You can access this reporting tool at any time via:
https://phoenixgroup-databreach.integrityplatform.org/
In order to explain the background to the reporting system in more detail, we have
also answered a number of frequently asked questions below:
When should I report an incident?
PHOENIX group has an obligation to notify the supervisory authority within 72 hours
of becoming aware of an incident, due to this, all incidents must be reported without
delay via the online reporting tool.
What data incidents should be reported and how?
All personal data incidents are to be reported to the Data Protection team via the
online reporting tool.
What is a data protection incident?
Data Protection incidents are any event which has, or could have, resulted in the
accidental or deliberate loss of personal data (electronic or paper) or destruction of
data, or unauthorised access to data (e.g. loss or theft of laptop, smartphone, paper
record, prescriptions).
What happens after I submit a report?
The Data Protection team will review the incident report and will contact you for
further information or, where necessary, will assist you with the post incident actions.

9. General Comments
We retain the right to change our data privacy statement. This may be necessary as
a result of technical developments. We therefore ask you to consult the data privacy
statement from time to time and to apply the current version.
If you have do have any further questions or concerns regarding you personal data,
please contact the designated data protection coordinator.
Date of last review and update: May 2018

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