Privacy Policy | Aptar Digital Health

Last update: June 2024

The website www.aptardigitalhealth.com (hereinafter the “Website”), published by Aptar Digital Health (hereinafter “ADH”), is the corporate website of ADH presenting its solutions and services.

While you are accessing, browsing, navigating and using the Website and its services, you communicate your personal data to ADH.

These personal data are protected by law. As a result, ADH, as data controller, has implemented appropriate security measures in order to protect your personal data.

Please read this privacy policy carefully as it explains how ADH uses your personal data and how to exercise your rights. This privacy policy supplements any documents or notices that may refer to this privacy policy.

Should you have any questions, you may directly contact ADH by sending an email to Informationgovernance@aptar.com.

1. What kind of personal data are processed by ADH?

All personal data provided by you via the Website or when you communicate with ADH are processed by ADH, namely:

Type of data	Examples of data
Identification data	Fist name, last name, company
Other personal data (not mandatory)	Job title, location, Free text⁽¹⁾ in the ‘message’ section of the contact form
Contact details	Email address, phone number
Data related to your exchanges with ADH	Therapeutic area of interest, Date and subject of your contact requests, exchanges with ADH’ services

⁽¹) It’s your responsibility to NOT SHARE SENSITIVE INFORMATION (about your health condition) through this chanel. Under no circumstances shall ADH be held liable for any indirect damage resulting from the use of the Website.

Also, the Website automatically collect the following data via cookies and other trackers:

Type of data	Examples of data	Purposes
Internet or other electronic network activity information (Traffic data)	Date and time of the visit, IP address, device unique identifier, device type, browser type, operating system, system configuration data, referring URLs, viewed pages and files	These data are necessary for the proper functioning of the Website and its website, as well as internal business analytics purposes such as audience measurement. For more information on cookies, please see the Cookies Policy of the Website.

The provision of certain types of personal data may be necessary or optional, depending on the services you wish to receive. Mandatory data will be marked as such during collection of your personal data. If you refuse to provide mandatory data, ADH may not be able to process your request.

2. For what PURPOSES does ADH use your personal data?

ADH processes your personal data for the following purposes only:

Purposes	Examples of use of your personal data	Legal bases
Managing the contact requests	to contact youto answer your questions	Legitimate interest of ADH to manage its contact requests
Improving the Website and its services, as well as your user experience on the Website	to evaluate and improve the Website and the services it providesto facilitate your navigation of the Website to take steps designed to protect the security of the Website	Legitimate interest of ADH to improve the Website and its services, as well as your user experience on the Website
Pre-litigation or litigation management (evidences)	to take action against any identified breachto manage any dispute or litigation	Legitimate interest of ADH in defending its rights and interests
Compliance with legal and regulatory obligations	to comply with legal and regulatory obligations to process your requests to exercise your rights	Legal and regulatory obligations to which ADH is subject
Newsletter campaigns (marketing)	to keep interested parties informed of the latest ADH news	Consent from user

3. Who can access your personal data?

Your personal data may be transmitted to the following recipients when you access, browse, navigate and use the Website and the services it provides:

Recipients	Purposes
ADH and its duly authorized employees	Management of the Website and its services
Companies of the Aptar Group and their duly authorized employees	Exclusively for administrative, operational, technical purposes, in particular for the processing of your job application
ADH’ service providers (hosting provider, IT service providers, etc.)	Exclusively for operational and technical purposes related to the management of the Website and its services
Administrative or judiciary authorities	Exclusively in the case of an express and justified request or in case of an alleged violation of legal or regulatory provisions
Lawyers and all interested parties	Exclusively in the case of the management of possible disputes and other legal matters where appropriate
Other third parties	Following or during a restructuring, reconstitution, acquisition, debt financing, merger, sale of assets of ADH or a similar transaction, as well as in case of insolvency, bankruptcy or receivership where personal data are transferred to one or more third parties as assets of ADH

4. Will your personal data be transferred outside of the EUROPEAN UNION/EUROPEAN ECONOMIC AREA?

As far as possible, your personal data are processed within the European Union (EU)/European Economic Area (EEA). However, ADH and some of ADH’ service providers being located outside of the EU/EEA, your personal information may therefore be processed in third countries.

When your personal data are transferred outside the EU/EEA, ADH will, in the absence of an adequacy decision and after having carried out an assessment of the level of protection of your rights on the territory of the third country where the recipient of your personal data is established, implement all necessary measures through the adoption of appropriate safeguards (such as standard contractual clauses). A copy of such safeguards can be obtained by sending an email directly to ADH at Informationgovernance@aptar.com.

Name of the recipient	Third country	Adopted safeguards
ADH LLC	United States	Technical and organizational measures in place
Aptar Group	United States	Technical and organizational measures in place

5. How does ADH protect your personal data?

ADH has implemented technical and organizational measures in order to protect your personal data, in particular against potential data breaches likely to cause, either by accident or unlawfully, the destruction, loss, modification, unauthorized access or divulgation of your personal data. These measures will guarantee a level of security adapted to the data and will consider the state of the art and the cost of implementation in relation to the risks and nature of the data to be protected.

ADH guarantees that all members of its personnel and any other person processing your personal data will respect the internal rules and procedures related to the processing of personal data, including the technical and organizational security measures put in place to protect your personal data. In this context, ADH reviews and updates its practices regularly to enhance your privacy and ensure that its internal policies are followed.

If you have found a vulnerability or would like to report a security incident, you may send an email to Informationgovernance@aptar.com.

6. For how long are your personal data STORED?

As a general rule, your personal data will only be retained for the period necessary for the accomplishment of the purposes for which said data was collected, or as necessary to fulfill legal or regulatory obligations.

In the absence of applicable exceptions:

the data collected via the contact form will be kept until the complete processing of your request;
if your job application is successful, the data collected in the context of your job application will be kept in accordance with the retention periods mentioned in the privacy policy for employees;
if your job application is unsuccessful, the data collected in the context of your job application will be kept for a period of two (2) years after our last contact with you, except in the event of request for deletion of your file;
your traffic data will be kept for a period of thirteen (13) months from the connection date.

In addition to this, ADH will keep your personal data for:

three (3) years for data processed for marketing purposes;
five (5) years for evidence purposes relating to legal claims;
ten (10) years from the end of the relevant fiscal year for personal data retained for accounting purposes as well as for commercial documents.

7. What are your rights regarding your personal data?

If you are based in the EU/ EEA, you have the following rights over your personal data:

you can request the access to your personal data in order to obtain clear, transparent and understandable information on how ADH processes your personal data and on your rights (as provided in this policy), as well as a copy of your personal data.

you can request the rectification of your personal data in order to obtain the modification of your personal data if theyareobsolete, inaccurate or incomplete ;

you can object to the processing of your personal data when the processing is based on ADH’ legitimate interest. ADH will no longer process your personal data unless ADH demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, such as the respect of a legal obligation (e.g. legal obligation involving the retention of documents), or for the establishment, exercise or defense of legal claims.

you can request the restriction of the processing during a limited period of time, in particular in order to carry out some verifications, where one of the following applies:

you contest the accuracy of your personal data, the processing of which is thus restricted for the period necessary for ADH to verify the accuracy of such personal data;
the processing is unlawful and, rather than requesting their deletion, you prefer to restrict their use;
ADH no longer needs your personal data for the purposes of the processing, but you need them for the establishment, exercise or defense of legal claims;
you have objected to the processing, which is thus restricted pending the verification of whether the compelling legitimate grounds of ADH may override your interests, rights and freedoms.

you can withdraw your consent when it has been obtained, without this withdrawal affecting the lawfulness of the processing operations previously carried out.

you can ask to receive your personal data in a structured, commonly used and machine-readable format and also can request their transmission to another controller where technically feasible. This right is not exercised in all circumstances, it applies only if it fulfils all the following conditions:

your request is only related to your personal data (excluding anonymous or third party data);
your request does not adversely affect the rights or freedoms of others, in particular those of ADH (including trade secrets or intellectual property);
the processing is carried out by automated means (paper files are therefore not included);
the processing is based on consent or the performance of a contract (to check if it is the case, you can see the article 2 of this policy).

you can request the deletion of your personal data (or right to be forgotten), where one of the following legal grounds applies:

you object to the processing of your personal data and there are no overriding legitimate reasons justifying to maintain the processing of your personal data (such as an obligation for ADH to keep certain personal data);
you object to marketing activities;
you decide to withdraw your consent on which the processing is based;
your personal data are no longer useful for the original purposes for which they were collected or for any other type of processing;
the use that is made of your data does not comply with the applicable legal or regulatory provisions.

You can define either general or specific guidelines regarding your personal data in the event of your death (for example, their deletion or transmission to any person of your choice). You may revoke your instructions at any time.

It is specified that the exercise of these rights is based on the legal basis of the processing as indicated in article 2 of this policy, as follows:

	Access	Rectification	Erasure	Restriction	Data portability	Objection
Consent	Yes	Yes	Yes	Yes	Yes	Withdrawal of consent
Steps prior to a contract			Yes		Yes	No
Contract			Yes		Yes	No
Legitimate interest			Yes		No	Yes
Legal obligation			No		No	No

Under certain circumstances, ADH may ask you for specific information in order to confirm your identity and ensure the exercise of your rights. This is another appropriate security measure to ensure that personal data is not disclosed to an individual who does not have the right to receive it.

If you have any questions or wish to exercise your rights, you may directly contact ADH by sending an email to Informationgovernance@aptar.com.

If needed, you may also lodge a complaint with your national data protection authority. This right may be exercised at any time and free of charge, at the exclusion of potential postal fees or expenses related to legal representation or assistance should you choose to engage third party assistance for the procedure.

8. Changes to this policy

This privacy policy may be amended from time to time, in particular to reflect the changes in the services provided by the Website or the applicable regulations. Therefore, we recommend you to review this privacy policy each time you visit the Website.