Privacy Policy

We are very pleased about your interest in our company. The management of Adragos Pharma GmbH places great importance on data protection. It is possible to use the Adragos Pharma GmbH website without providing any personal data. However, if a person concerned wishes to make use of special services of our company via our Internet site, it may become necessary to process personal data. If it is necessary to process personal data and there is no legal basis for such processing, we generally obtain the consent of the person concerned.

The processing of personal data, for example the name, address, e-mail address or telephone number of a person concerned, is always carried out in accordance with the basic data protection regulation and in compliance with the country-specific data protection regulations applicable to Adragos Pharma GmbH. By means of this data protection declaration, our company wishes to inform the public about the type, scope and purpose of the personal data collected, used and processed by us. Furthermore, this data protection declaration informs affected persons about the rights to which they are entitled.

Adragos Pharma GmbH, as the person responsible for processing, has implemented numerous technical and organizational measures to ensure that the personal data processed via this website is protected as completely as possible. Nevertheless, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, every person concerned is free to transmit personal data to us by alternative means, such as by telephone.

1. Definitions

The data protection declaration of Adragos Pharma GmbH is based on the terminology used by the European legislator for directives and regulations when the basic data protection regulation (DS-GVO) was issued. Our data protection declaration should be easy to read and understand for the public as well as for our Adragos Pharma GmbH and business partners. To ensure this, we would like to explain the terms used in advance.

We use the following terms, among others, in this data protection declaration:

(a) Personal data

Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as ‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

(b) The person concerned

Data subject means any identified or identifiable natural person whose personal data are processed by the controller.

(c) Processing

Processing is any operation or set of operations, performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, organisation, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

(d) Restriction on processing

Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.

(e) Profiling

Profiling is any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, conduct, location or change of location.

(f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without additional information, provided that this additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data is not attributed to an identified or identifiable natural person.

(g) Controller or data controller

Controller or data controller shall mean the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union law or by the law of the Member States, provision may be made for the controller or for the specific criteria for his or her designation in accordance with Union law or the law of the Member States.

(h) Processors

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

(i) Recipient

The recipient is a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not it is a third party. However, authorities which may receive personal data in the course of a specific investigation, in accordance with Union or national law, shall not be considered as recipients.

(j) Third party

Third party means any natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or the processor, are authorized to process the personal data.

(k) Consent

Consent shall mean any freely given specific and informed expression of the data subject’s will in an informed and unequivocal manner, in the form of a declaration or other unequivocal affirmative act by which the data subject signifies his or her consent to the processing of personal data relating to him or her.

2. The name and address of the controller

The person responsible within the meaning of the basic data protection regulation, other data protection laws applicable in the member states of the European Union and other provisions of a data protection nature is the:

Adragos Pharma GmbH
Sonnenstraße 17, 80331 Munich, Germany
Phone: +49 (0)89 262 022 920
e-mail: info@adragos-pharma.com
Website: www.adragos-pharma.com

3. The name and address of the data protection adviser

is the data protection advisor of the controller: Andreas Raabe

Adragos Pharma GmbH
Sonnenstraße 17, 80331 Munich, Germany
Phone: +49 (0)89 262 022 920
e-mail: info@adragos-pharma.com
Website: www.adragos-pharma.com

Every person concerned can contact our data protection advisor directly at any time with all questions and suggestions regarding data protection.

4. Collection of general data and information

The website of Adragos Pharma GmbH collects a number of general data and information with every call to the website by a person concerned or an automated system. This general data and information is stored in the server’s log files. The following can be recorded: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites that are accessed via an accessing system on our website, (5) the date and time of an access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information which serve to prevent danger in the event of attacks on our information technology systems.

When using this general data and information, Adragos Pharma GmbH does not draw any conclusions about the person concerned. Rather, this information is required in order to (1) deliver the contents of our website correctly, (2) optimize the contents of our website and the advertising for it, (3) ensure the permanent operability of our information technology systems and the technology of our website, and (4) to provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack. These anonymously collected data and information are therefore evaluated by Adragos Pharma GmbH on the one hand statistically and also with the aim of increasing data protection and data security in our company, in order to ultimately ensure an optimum level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by a person concerned.

5. Contact possibility via the internet page

Due to legal regulations, the website of Adragos Pharma GmbH contains information that enables rapid electronic contact with our company and direct communication with us, which also includes a general address for so-called electronic mail (e-mail address). If a data subject contacts the data controller by e-mail or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted voluntarily by a data subject to the controller are stored for the purposes of processing or contacting the data subject. Such personal data shall not be disclosed to third parties.

6. Routine deletion and blocking of personal data

The controller shall process and store personal data relating to the data subject only for the time necessary to achieve the purpose of storage or where provided for by the European Directive and Regulation or by any other law or regulation to which the controller is subject.

If the purpose of storage ceases to apply or if a storage period prescribed by the European Directive and Regulation Giver or any other competent legislator expires, the personal data will be blocked or deleted as a matter of routine and in accordance with the statutory provisions.

7. Rights of the data subject

(a) Right to confirmation

Every data subject has the right, granted by the European Directives and Regulations, to obtain confirmation from the controller as to whether personal data relating to him are being processed. If a data subject wishes to exercise this right of confirmation, he or she may at any time contact an employee of the controller.

(b) Right to information

Any person affected by the processing of personal data has the right, granted by the European Directives and Regulations, to obtain at any time and free of charge from the controller information on the personal data stored in relation to him or her and a copy thereof. Furthermore, the European Directive and Regulation Giver has granted the data subject access to the following information:

the processing purposes
the categories of personal data processed
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular to recipients in third countries or to international organisations
if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
the existence of a right of rectification or erasure of personal data relating to them or of a right of objection to their processing by the controller
the existence of a right of appeal to a supervisory authority
if the personal data are not collected from the data subject: All available information on the origin of the data
the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) of the DPA and, at least in these cases, meaningful information about the logic involved and the scope and intended impact of such processing on the data subject
The data subject shall also have the right to obtain information as to whether personal data have been transferred to a third country or to an international organisation. If this is the case, the data subject shall also have the right to obtain information on the appropriate safeguards in relation to the transfer.
If a data subject wishes to exercise this right of access, he or she may at any time contact a member of the staff of the controller.

(c) Right of rectification

Every person concerned by the processing of personal data has the right, granted by the European legislator, to request the rectification without delay of inaccurate personal data concerning him. The data subject shall also have the right to request the completion of incomplete personal data, including by means of a supplementary declaration, having regard to the purposes of the processing.

If a data subject wishes to exercise this right of rectification, he or she may at any time contact an employee of the controller.

(d) Right of cancellation (right to be forgotten)

Any person affected by the processing of personal data has the right, granted by the European Directives and Regulations, to obtain from the controller the immediate erasure of personal data relating to him/her, where one of the following reasons applies and provided that the processing is not necessary:

the personal data have been collected or otherwise processed for purposes for which they are no longer necessary

The data subject withdraws the consent on which the processing was based pursuant to Article 6(1)(a) of the DPA or Article 9(2)(a) of the DPA, and there is no other legal basis for the processing.

The data subject lodges an objection to the processing pursuant to Article 21(1) DPA and there are no overriding legitimate reasons for the processing, or the data subject lodges an objection to the processing pursuant to Article 21(2) DPA.

The personal data were processed unlawfully.

The deletion of the personal data is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.

The personal data were collected in relation to information society services offered in accordance with Article 8 (1) DS-GVO.

If one of the above reasons applies and a data subject wishes to have personal data stored by Adragos Pharma GmbH deleted, he/she may contact an employee of the data controller at any time. The employee of Adragos Pharma GmbH will ensure that the request for deletion is complied with immediately.

If the personal data has been made public by Adragos Pharma GmbH and our company is responsible as the data controller in accordance with Art. 17 Par. 1 DS-GVO, Adragos Pharma GmbH will take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform other data controllers who process the published personal data that the person concerned has requested these other data controllers to delete all links to this personal data or copies or replications of this personal data, unless the processing is necessary. The employee of Adragos Pharma GmbH will take the necessary steps in individual cases.

(e) Right to limit processing

Any person affected by the processing of personal data has the right, granted by the European Directives and Regulations, to request the controller to restrict the processing if one of the following conditions is met:

the accuracy of the personal data is contested by the data subject, for a period of time sufficient to enable the controller to verify the accuracy of the personal data

The processing is unlawful, the data subject refuses to have the personal data deleted and instead requests the restriction of the use of the personal data.

The controller no longer needs the personal data for the purposes of the processing, but the data subject needs them in order to assert, exercise or defend legal claims.

The data subject has lodged an objection to the processing in accordance with Article 21 (1) of the DPA and it is not yet clear whether the legitimate reasons given by the controller outweigh those of the data subject.

If one of the above-mentioned conditions is met and a data subject wishes to request the restriction of personal data stored by Adragos Pharma GmbH, he/she may contact an employee of the data controller at any time. The employee of Adragos Pharma GmbH will arrange for the restriction of the processing.

(f) Right to data portability

Every person concerned by the processing of personal data has the right, granted by the European Directives and Regulations, to receive the personal data concerning him/her which have been provided by the data subject to a controller in a structured, common and machine-readable format. He/she also has the right to have this data communicated to another controller without hindrance by the controller to whom the personal data has been made available, provided that the processing is based on the consent pursuant to Art. 6(1)(a) DPA or Art. 9(2)(a) DPA or on a contract pursuant to Art. 6(1)(b) DPA and that the processing is carried out by means of automated procedures, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, when exercising their right to data transferability in accordance with Art. 20 Paragraph 1 FDPIC, the data subject has the right to obtain that personal data be transferred directly from one controller to another controller, insofar as this is technically feasible and provided that this does not adversely affect the rights and freedoms of other persons.

In order to assert the right to data transfer, the person concerned can contact an employee of Adragos Pharma GmbH at any time.

(g) Right of appeal

Every person concerned by the processing of personal data has the right, granted by the European legislator for directives and regulations, to object at any time, for reasons arising from his or her particular situation, to the processing of personal data concerning him or her that is carried out on the basis of Article 6(1)(e) or (f) of the DPA. This also applies to profiling based on these provisions.

In the event of an objection, Adragos Pharma GmbH will no longer process the personal data unless we can prove compelling reasons for processing worthy of protection that outweigh the interests, rights and freedoms of the person concerned, or the processing serves to assert, exercise or defend legal claims.

If Adragos Pharma GmbH processes personal data for the purpose of direct advertising, the person concerned has the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling, insofar as it is connected with such direct advertising. If the data subject objects to Adragos Pharma GmbH processing for the purposes of direct advertising, Adragos Pharma GmbH will no longer process the personal data for these purposes.

In addition, the data subject has the right to object, for reasons arising from his or her particular situation, to the processing of personal data concerning him or her that takes place at Adragos Pharma GmbH for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 para. 1 of the DS-GVO, unless such processing is necessary for the performance of a task in the public interest.

To exercise the right of objection the data subject may directly contact any employee of Adragos Pharma GmbH or any other employee. The data subject is also free to exercise his/her right of objection in connection with the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures involving technical specifications.

(h) Automated case-by-case decisions including profiling

Every person concerned by the processing of personal data has the right, as granted by the European Directives and Regulations, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or significantly affects him or her in a similar way, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorised by Union or national legislation to which the controller is subject and that such legislation provides for adequate safeguards of the rights and freedoms and legitimate interests of the data subject, or (3) is taken with the explicit consent of the data subject.

If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the data controller or (2) is taken with the express consent of the data subject, Adragos Pharma GmbH shall take appropriate measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject, which shall include at least the right to obtain the intervention of a person from the data controller, to present its own position and to challenge the decision.

If the data subject wishes to exercise rights relating to automated decisions, he or she may at any time contact a member of the staff of the controller.

(i) Right to revoke a data protection consent

Every person affected by the processing of personal data has the right, granted by the European Directive and Regulation Giver, to revoke his or her consent to the processing of personal data at any time.

If the data subject wishes to exercise his or her right to withdraw consent, he or she may at any time contact an employee of the controller.

8. Legal basis of the processing

Art. 6 I lit. a DS-GVO serves our company as a legal basis for processing operations for which we obtain consent for a specific processing purpose.

9. Legitimate interests in the processing pursued by the controller or a third party

If the processing of personal data is based on Article 6 I lit. f DS-GVO, our legitimate interest is to carry out our business activities for the benefit of the well-being of all our employees and our shareholders.

10. The period for which the personal data are stored

The criterion for the duration of storage of personal data is the respective legal retention period. After expiry of this period, the corresponding data is routinely deleted, provided that it is no longer required for the fulfilment of the contract or the initiation of a contract.

11. Legal or contractual provisions making the personal data available; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of not providing the data

We would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual regulations (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded that a data subject provides us with personal data, which must subsequently be processed by us. For example, the person concerned is obliged to provide us with personal data if our company concludes a contract with him/her. Failure to provide the personal data would mean that the contract with the person concerned could not be concluded. Before the person concerned makes personal data available, he or she must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences would be if the personal data were not provided.

12. The existence of automated decision making

As a responsible company, we avoid automatic decision making or profiling.

Status: April 2023