1. General

This Privacy Policy describes how Exeltis Pharmaceuticals Holding, S.L. and all its subsidiaries located in Spain, EU or third countries (hereinafter, jointly referred to as “Exeltis”) manage and process the information collected from you (the “User”) when registering or navigating through the website https://exeltis.com/entwine/ (hereinafter, the “Website”), owned by Insud Pharma. Please read carefully this Privacy Policy as it contains important information concerning the personal data of Users and how we use it.

Exeltis and all its subsidiaries located in Spain, EU or third countries are globally known as Insud Pharma Group (hereinafter, “Insud Pharma Group”). Please find additional information about Insud Pharma Group and a non-exhaustive list of Exeltis subsidiaries here.

Exeltis dedicates all its efforts to respect the privacy and security of the Users and undertakes to use personal data in accordance with the General Data Protection Regulation (“GDPR“) and national data protection law.

The identification of the data controller and the data protection officer are the following:

Corporate name	Exeltis Pharmaceuticals Holding, S.L.
Registered office	Calle Manuel Pombo Angulo, 28 3ª planta 28050 Madrid, España.
Tax Identification Number	B-86841079
Telephone	+34 917711500
Email	dataprotection@insudpharma.com
Companies House Information	Commercial Registry of Madrid, Page M-566737, Volume 31.484, Sheet 160

2. Categories of Personal Data and Purposes of the Processing

Users may use some functionalities of the Website without having to provide Exeltis any personal data. However, for certain functions, Users shall provide personal data in order to register for certain services, receive newsletters or other information of interest. In addition to the information you provide directly to Exeltis, we collect certain information when you visit our Website.

Personal data collected through the Website will be duly incorporated in databases under the responsibility of Exeltis which will be registered in Exeltis’ record of processing activities.

We also inform the Users that fields requested in forms marked with an asterisk (*) are mandatory. In this sense, if the requested information is not provided, we will not be able to carry out the service.

Below, we have specified the categories of personal data we collect, the purposes for which we use such data and how long we will keep the personal data:

A. Users Communications

This category includes any personal data provided by the User during their communications with Exeltis for the purpose of solving any doubt, suggestion or claim. In this sense, if the User has made any request or suggestion through our contact channels, we will process the personal data in order to answer it.

For the fulfilment of this purpose Exeltis may engage third services providers to ensure the confidentiality and privacy of users when managing and solving their requests. In any case, these third entities shall act as data processors and shall follow Exeltis’ instructions when accessing to personal data of users. No personal information that may identified the Users will be made available or communicated to Exeltis.

These questionnaires and Website are not intended for including Users’ profile in a clinical trial. In case the User is interested in participating in some of the clinical trial announced on the Website, the User shall need to access to the specific landing page of the clinical trial to obtain detailed information and submit its interest in participating.

The legal basis for the processing of these personal data is the consent voluntarily shown by the Users when providing their data through the form provided for this purpose and sending their requests.

B. Information About the Use of Our Website

Exeltis collects information automatically obtained by the Website related to the identification of the User’s computer equipment, use and navigation habits.

Said information includes data regarding language, pages or sections of the Website, keywords, date, time, amount of time the User expends in certain types of webpages, which section of the page he has visited, and similar information related to the use of the Website. Exeltis may collect this information using cookies. To obtain additional information please visit our Cookies Policy.

We use this personal data based on our legitimate interest in order to improve our services and User’s experience on the Website, as well as based on the consent shown by the User through cookies settings. We will keep the Personal Data for 1 month from the date of the last visit to the Website.

Exeltis may combine your personal data with other information provided by the User or collected from the Website as above mentioned. In those cases, all combined information will be processed as personal data during the period the information remains combined.

C. Website Maintenance and Optimization

Users’ personal data will also be used for the maintenance and analysis of our Website, solve any problem, improve availability and protect the Website against fraud (e.g. in case of repeated log attempts or non-compliance with our terms and conditions, e.g. by persons under the age of 18). Analytics also allow us to check whether the online services we offer work effectively in order to improve them whenever possible.

The use of User’s personal data for these purposes is necessary based on our legitimate interest and will be retained for a maximum period of 6 months.

D. Comply with our Legal Obligation

We may need to process your personal data to comply with legal obligations binding or accepted by us. Likewise, we may need to provide information to and as required by local law enforcement agencies, other government authorities, or otherwise required by law or to protect the rights and safety of our property, company, employees and customers.

3. How We Share Personal Data

Sometimes it is necessary to share your personal data with third parties in order to guarantee the correct provision of the services. We may share such information with the following:

• Insud Pharma Group companies due to the use of shared computer systems, which may be located in the European Economic Area (EEA) or in third countries.
• Service providers, acting as data processors, to the extent necessary for the provision of a service. In particular, Exeltis has engaged Women Hub, S.L. for the correct management and response to requests submitted through the Website as well as, if required, to contact Users to provide them with information requested.
• Competent authorities: in case of legal requirement or obligation, as well as for the defence and exercise of rights, it may be necessary to communicate data to the competent authorities in each case.

Such entities may be located in Spain, other countries in the EEA or anywhere else in the world. When we keep personal data outside the EEA, we guarantee an adequate level of protection of the transferred data. To this purpose, we require service providers to take appropriate measures to protect the confidentiality and security of personal data.

For example, for services provided by providers outside the European Economic Area, we use Standard Model Clauses approved by the European Commission.

Exeltis may disclose User’s personal data to any public administration, when required by law and compelled to do so by such authorities. All data communications will always be carried out in compliance with the GDPR and the national data protection law.

4. Retention of Personal Data

We will keep your personal data for as long as it is necessary to fulfil the purposes described in this Privacy Policy. In any case, we will keep your personal data as long as you do not withdraw the consent previously granted.

Personal data collected through the use of cookies will be kept for the period of time indicated in the Cookie Policy. Once these periods have expired, your data will be deleted.

5. Security

Exeltis cares to ensure the security and confidentiality of the Users personal data. Therefore, we have taken several security measures and technical means to prevent the loss, misuse or access to the personal data without the User permission in accordance with GDPR and the national data protection law.

Nevertheless, it is also the User responsibility to control his or her personal information, therefore Exeltis asks and encourages all Users to be careful sharing information and content. Exeltis shall not control the content and information the User chooses to share with other Users and, therefore, Exeltis is not responsible for the consequences of the Users own actions.

Exeltis pledges (i) to act rapidly and in a responsible manner in the event the Users personal data security is deemed at risk, and (ii) to report it if relevant with the greatest diligence.

In case of a personal data breach, Exeltis undertakes to notify the Spanish Data Protection Agency or the relevant data protection authority without undue delay after becoming aware of such breach. Likewise, when the personal data breach is likely to result in a high risk to the rights and freedoms of Users, Exeltis will communicate the personal data breach and the measures taken to mitigate the risks and adverse effects to Users.

6. Cookies

Much of the information referred to in this Privacy Policy is collected through the use of cookies. Cookies are small text files containing small amounts of information that are downloaded and can be stored on your user device, for example, your computer, smartphone or tablet.

These cookies are sometimes necessary to remember your account settings, language and country, but they also allow us to track and analyse Users behaviour on our Website and to display personalised advertisements on our Website or on third party websites. Where necessary, you will be asked to consent to the use of cookies. To obtain additional information on how cookies are used in the Website and its deactivation please visit the Cookies Policy.

7. Minors

The Website is not intended to be used by persons under the age of 18. Under no circumstances Exeltis will voluntarily collect personal data from persons under the age of 18.

8. Users Rights Concerning Data Protection

At any time, Users may exercise before Exeltis their data protection rights, in particular the right of access, rectification, restriction of processing, erasure, objection and portability pursuant to the applicable legislation. This means Users can ask what personal data we have about them, update, or they can request that Exeltis stops using data for a specific purpose, or simply require Exeltis to delete all personal data from our files and databases among other.

In the event the User decides to object to the processing of the personal data, Exeltis will no longer process personal data in connection to such User. Personal data may still be processed for the purposes established in data protection legislation or bring defence against legal claims.

After the User exercises any of the abovementioned rights, and during Exeltis verification period, all personal data will be kept blocked. The blocking procedure will prevent Exeltis from processing or erasing such personal data.

For the exercise of any of the abovementioned rights, the User shall contact Exeltis by email, addressing the request to dataprotection@insudpharma.com indicating as reference: “EXERCISE OF RIGHTS” and identifying the right to be exercised. In addition, Users may also lodge a claim before the Spanish Data Protection Agency (www.aepd.es) or the relevant data protection authority if they consider that we have not processed their personal data in accordance with the regulations.

9. Users Erasure Right

As User, at any time you have the possibility to exercise your right to object to the processing of your personal data by sending an email todataprotection@insudpharma.com with the subject “DATA ERASURE”.

10. Privacy Policy Updates

Exeltis reserves the right, at our sole discretion, to modify or replace this Privacy Policy. Your continued use of the Website after any such changes constitutes your acceptance of the new Privacy Policy.

Please review this agreement every so often in order to acknowledge any possible modifications. If you do not accept this document, partially or as a whole, or any subsequent modification, please refrain from the use, access or continue to access the Website or discontinue any use of the Website immediately.

11. Contact

If you have any further questions about the use of your personal data or about our Privacy Policy, you can contact Exeltis’ Data Protection Officer by email through dataprotection@insudpharma.com