ONLINE PRIVACY NOTICE

BACKGROUND:

Luna Pharma Consulting Ltd. (“the Company”, “we”, “us”, “our”) understands that your privacy is important to you and that you care about how your personal data is used.

You can navigate most of our website without being required to provide any personal information. However, in the events you require further information  or services from us, by filling in the contact form available on our website, or by directly sending an email to us, or while applying for a job on our website, you would be providing us with your personal data.

We respect and value your privacy. With the aim of protecting your privacy, we prepared this notice to explain what kind of personal data we may collect and process and what choices you can make about the way your information is collected and used.

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 notice applies where we are acting as a data controller in respect of the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data. It contains information on how we hold and process our website visitors’ personal data, and their rights under the law relating to their 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 the personal set out in the table below, using the methods also set out in the table. We do not collect any “special  category” or “sensitive” personal data (such as health, sexual orientation, race, ethnic origin, political opinion, religion, trade union membership and genetic and biometric data) and personal data relating to children and data relating to criminal convictions and/or offences.

Data Collected

Personal details including name, address, email address, telephone number

Contact information of job applicants including:

Name, address, telephone number, email address, CV, and any other personal data the job applicant provides (such as job title, employer name and alike)

How We Collect Data

Via Contact Form submission on our website and via direct email.

Via Contact Form submission on our website and via direct email.

 6.  How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following describes how we may use your personal data, and our lawful bases for doing so:

  • We may process information contained in any contact form you submit to us through our website (“contact form data”). The contact form data may be processed for the purposes of getting in touch with you and responding to your queries or requests for additional information on our services. The legal basis for this processing is your consent.

  • We may process information contained in any email you sent to us directly, in order to respond to your requests or queries detailed in your email to us. The legal basis for this processing is legitimate interest.

  • We may process job applicants’ personal data, as part of our recruitment processes. We may for example, need to assess and record information about a job applicant’s qualifications as part of the selection process; or process relevant data for checking if a successful candidate has the right to work in the UK. The legal basis for processing a job applicant’s data is our legitimate interest.    

 

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 for information about how we use any personal data provided via cookies on our website.

13. Changes to this Privacy Notice

         

Any changes will be made available on our website: www.lunapharmaconsulting.com. This Privacy Notice was last updated on 17/05/2021.