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Privacy Policy

Last update: Dec 2022

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 questionsyou 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 dataExamples of data
Identification dataFist name, last name, company
Contact detailsEmail address, phone number
Data related to your exchanges with ADHDate and subject of your contact requests, exchanges with ADH’ services
Data related to your job application (“Join us” section)Resume, cover letter, current job, professional experiences, education, photography

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

Type of dataExamples of dataPurposes
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 filesThese 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:

PurposesExamples of use of your personal dataLegal bases
Managing the contact requests·       to contact you
·       to answer your questions
Legitimate interest of ADH to manage its contact requests
Managing your job application(“Join Us” section)·       to examine your job application
·       to contact you·       to organize an interview
To take steps prior to contract
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 provides
·       to 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 breach
·       to 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 newsConsent 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:

RecipientsPurposes
ADH and its duly authorized employeesManagement of the Website and its services
Companies of the ADH Group and their duly authorized employeesExclusively 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 authoritiesExclusively 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 partiesExclusively in the case of the management of possible disputes and other legal matters where appropriate
Other third partiesFollowing 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 recipientThird countryAdopted safeguards
ADH LLCUnited StatesTechnical 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:

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

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 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 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:

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

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:

AccessRectificationErasureRestrictionData portabilityObjection
ConsentYesYesYesYesYesWithdrawal of consent
Steps prior to a contractYesYesNo
ContractYesYesNo
Legitimate interestYesNoYes
Legal obligationNoNoNo

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.

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