BACKGROUND:

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As Luna Pharma Consulting Ltd. (also referred to as the “Company”, “we”, “us”, “our”), we respect the relationship with our clients and the privacy of all types of personal data we process for the provision of our services and carrying out our business operations.

           

This Policy explains how we collect, hold, process and disclose personal data including personal data of (the individuals who represent or represented)                our clients, business contacts, contractors, consultants and employees. (collectively will be referred to as “you”).

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1.   Information About Us

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We are a private limited company registered in England and Wales under registration number 10241868, and our registered office is at:

The House, High Street,

Tonebridge, Brenchley,

Kent TN12 7NQ.

The Company’s Data Protection Officer (“DPO”) is: Izabela Braula

email address: 

izabela.braula@lunapharmaconsulting.com

postal address:

25 Eccleston Place,

SW1W 9NF London (“principal place of business”).

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2.   What Does This Notice Cover?

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This Privacy Notice applies to all personal data of Individuals, either in electronic or paper format, received by Luna Pharma, including personal data of      individuals who represent (or represented) Luna Pharma’s clients, potential clients, business contacts, contractors, consultants and employees. It explains how such personal data is collected, held and processed. It also explains your rights under the law relating to your personal data.

 

3.   What Is Personal Data?

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Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as “any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier”.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

 

4.    What Are My Rights?

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Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

• The right to be informed about our or collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.

• The right to access the personal data we hold about you. Part 10 will tell you how to do this.

• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.

• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.

• The right to restrict (i.e. prevent) the processing of your personal data.

• The right to object to us using your personal data for a particular purpose or purposes.

• The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

• The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance  of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

• Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

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For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

The ICO’s address:           

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

 

We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.

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5.   What Personal Data Do You Collect and How?

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We may collect and hold some or all of your personal data, including:

• Your personal details including name, address, e-mail address, phone numbers,

• Your location and the country you reside in,

• Job related information such as your job title, job description, who you report to, your employer,

• Records of your contacts with us.

           

We will not process any “sensitive personal data” for the purposes other than for which the information was originally obtained (most of the time, only in respect of our employees) or subsequently authorized by the relevant individual, unless the individual explicitly consents to such processing, as required or permitted, or where not prohibited by law or regulation.

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Types of “sensitive personal data” we may hold as per above, may include:

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• All government-issued identification numbers (including national insurance numbers, EU and non-EU country specific social security numbers, driver’s license numbers, and passport numbers);

• All financial account numbers (bank account numbers, credit card numbers, and other information if that information would allow access when combined with the account/card numbers); 

• Medical records, including any information on any employee’s or other individuals’ health, disability, disease or product interests;

• Reports of individual background checks;

• Sexual orientation, race, ethnic origin, political opinion, religious or philosophical beliefs, trade union membership and genetic and biometric data.

 

We do not collect personal data relating to children and data relating to criminal convictions and/or offences.

 

6.    How Do You Use My Personal Data?

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We collect and process your personal data on the basis of one of the six lawful reasons permitted by the Data Protection Legislation. In general, with exceptions such as where we rely on your consent and other lawful bases that may be relevant for any specific service notice, we process personal data relying on performance of contracts and our legitimate interests consistent with applicable law.