PRIVACY NOTICE FOR CLIENTS & OTHERS

 BACKGROUND:

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”).

1.   Information About Us

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”).

2.   What Does This Notice Cover?

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?

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?

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.

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.

5.   What Personal Data Do You Collect and How?

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.

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

  • 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?

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.

What We Do
What Data We Use
Our Lawful Basis

Communicate with Potential Clients and Clients, Contractors, Consultants, Business Contacts other than the representatives of the former.

Name,

Telephone Number,

Email Address,

Address

Job title,

Job Description,

Employer name,

Financial data such as invoices, bank details, VAT numbers etc.

Legitimate interest to discuss potential business opportunities, enter into a contract, performance of our contractual obligations, general communication. For business contacts, there may also be consents obtained. 

Hold and process employee/HR data

Name

Job Title

Address

Phone Number

Email

Contracts

Payslips

Bank Account Details

Expenses

Any other consented sensitive personal data

Our legitimate interest to carry out and support our human resources functions and activities, comply with applicable law and regulations, consents in relation to the occasional processing of the sensitive personal data.

Our legitimate interest to carry out and support our human resources functions and activities, comply with applicable law and regulations, consents in relation to the occasional processing of the sensitive personal data.

 

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

 

7.    How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

Please refer to Data Retention Policy for more information.

 

 

8.   How and Where Do You Store or Transfer My Personal Data?

We will store your personal data in the UK at our registered offices, at the principal place of business or at our liaison office in Istanbul, Turkey. We ensure that your data is fully protected under the Data Protection Legislation and that we will take additional steps to ensure that your personal data in Turkey is treated just as safely and securely as it would be within the UK. In this respect, we ensure that your personal data is protected under binding corporate rules as per Article 47 of the UK GDPR. Binding corporate rules are a set of common rules which all Luna Pharma businesses are required to follow when processing personal data. For further information, please refer to the guidance on the Information Commissioner’s Office’s website or get in touch with us.

 

The security of your personal data is essential to us and to protect your data, we take a number of important measures, including, but not limited to, the following:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need-to-know basis and ensuring that they are subject to duties of confidentiality;

  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

 

9.    Do You Share My Personal Data?

In some limited circumstances, we may share your personal data as described here or with your permission. 

  • We may share your personal data with our service providers including those for the (i) provision of IT and related services; (ii) provision of website hosting services. We may also disclose your personal data to our professional advisors insofar as reasonably necessary for the purposes of obtaining professional advice.

  • We may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

 

Luna Pharma ensures that there are appropriate contracts with the service providers and business partners that prohibit them from using or sharing personal data except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the UK, will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.

10.  How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use.

You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 3 weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

 

11.  How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including filing a subject access request, please use the following details; for the attention of:

Data Protection Officer:  Izabela Braula

Email address:

izabela.braula@lunapharmaconsulting.com

Postal Address:

25 Eccleston Place,

SW1W 9NF London.

 

12.  About Cookies

Please refer to Luna Pharma's Cookie Policy available on our website for information about how we use any personal data provided via cookies on our websites.

 

13.  Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website: www.lunapharmaconsulting.com.

 

This Privacy Notice was last updated on 17/05/2021.