Privacy Policy
This privacy policy describes the ways in which Farmindustria, the Italian Association of
Pharmaceutical Companies, a professional and trade organisation (hereinafter also
"Farmindustria" or "the Association"), collects and processes personal data ofvisitors/users who navigate on the website www.farmindustria.it (hereinafter, also the"Site").
Pursuant to art. 13 of EU Reg. 2016/679, Farmindustria, as"Data Controller", is required to
inform data subjects, to whom the data refer, about the type of data processed and toprovide certain elements qualifying the processing, in full compliance with the privacy
legislation on the protection of personal data and the corresponding regulatory provisions(EU Regulation 2016/679 (GDPR); Italian Legislative Decree 196/2003 as amended (thePrivacy Code).
The attention to privacy, confidentiality and protection of users’ personal data is consideredby the Association a relevant task to be perused. Consequently, the personal data areprocessed with the utmost care, in compliance with the principles of lawfulness,transparency and confidentiality, and in accordance with current data protection andsecurity legislation.
This Privacy Policy is provided solely for the institutional site of Farmindustria, identified
above, and not concern any other websites that may be consulted by the user through links
from this website.
Other internet addresses to which this site may conduct the user could contain tracking
systems unrelated to Farmindustria.
Farmindustria, therefore, does not guarantee that these external sites are equipped withappropriate security systems aimed at protecting the data processed and is therefore notresponsible for the content of these sites or for any processing of personal data carried out
on such sites. It is therefore necessary to examine the notice provided on each website
linked to this one to identify any possible processing of personal data and the related
measures adopted.
Site users/visitors are invited to carefully read this Privacy Policy before disclosing any typeof information/personal data and/or filling in any form present on the website.
Nature of the personal data processed
Access to certain sections of the website and/or any requests for information or services
made by users of the website may require to entry personal data, which will be processedby Farmindustria (the "Data Controller") in compliance with the privacy legislation
concerning personal data protection.

The data collected through the site are personal data relating directly to the data subject(name, surname, etc.) and contact data (email, telephone number), and as such fall into
the category of "personal data" pursuant to art. 4, paragraph 1 of the GDPR.
No special categories of data are normally processed, as defined pursuant to art.9 of theGDPR, nor is any judicial data; in any case, should it become necessary to process thesetypes of data, the Association will proceed with the processing after the acquisition of theuser/data subject’s consent.
Purposes and legal basis of the processing
Depending on the needs expressed in each case by the user accessing the various sectionsof the website, the personal data provided directly by users by filling out the online forms
may be processed for the following purposes:a) to permit, by filling in a specific form in the "Work with Us" section of the Site (for whichreference is made to the specific privacy notice) - the collection of personal data of users
who intend to apply for a job position at Farmindustria, and information concerning theirprofessional experience, organised in the form of a curriculum vitae (CV). The processingof such data is therefore aimed at searching for and selecting personnel for Farmindustria’s
own organisation or that of its member companies, and for management of this service,functional to the fulfilment of pre-contractual obligations. (art.6, para.1, lett. b) GDPR);b) to carry out communication and promotional activities (such as, sending promotional
information and invitations to events, etc.), also by e-mail, without prejudice to the data
subject’s rightto object to the processing of the data at any time. Such processing is carried out on thebasis of the legitimate interest (Article 6, paragraph 1, lett. f) GDPR) of the Data Controller
to inform users who visit the Association’s website about the main initiatives anddevelopments in the pharmaceutical industry, through the sending of communications forinformation and promotional purposes.
In compliance with national and EU legislation, a better detailed in the Association’s
Articles of Association, made public on its website, Farmindustria pursues the following
goals, among others: Promotion of scientific research in the pharmaceutical field at alllevels, reinforcement and legislative protection of scientific research in the pharmaceuticalindustry, development of a market based on the principles of free competition, in particularthrough the implementation of appropriate policies concerning pricing and recognition of
the value of innovation, collaboration with the competent authorities for the study andimplementation of regulations concerning the sector.
For the purposes of pursuing its statutory goals, it is essential to communicate and provide
information on the Association’s activities and initiatives to the public, to the authorities, tovarious social players, to member companies and to the various institutions.

The personal data acquired are therefore processed for the following purposes:— For all aspects of statutory, administrative and general association management;— For the sending of communications and of invitations to meetings, events, courses, andconferences, as well as the sending of promotional material on courses and workshops
through newsletters;— For any other institutional activities promoted by Farmindustria in accordance with its
articles of association.
The processing activities described above are carried out on the basis of the assumptionthat the user is interested in staying up to date on the most significant news, while offering
the user the option of objecting to the receipt of these communications by means of theappropriate link placed on the bottom of the communications sent by email.
Categories of personal data subject to processing and methods of processing
Browsing data
The computer systems and software procedures used to operate this website acquire,in the course of their normal operation, certain items of personal data that are thenimplicitly transmitted in the use of internet communication protocols.
Such information could, due to its very nature, through association and processing of data
held by third parties, permit the identification of users/visitors (e.g. IP address, domainnames of computers used by users/visitors who connect to the site, addresses in URI –Uniform Resource Identifier – notation of the requested resources and other parametersconcerning the operating system and the IT environment used by the user).
Such data, not associated with directly identifiable users, are processed, for the timestrictly necessary, for the sole purpose of obtaining anonymous statistical information on
the use of the site and to check its smooth operation.
Data provided voluntarily by users
Farmindustria acquires personal data directly from users through:a) the voluntary sending by the user of e-mails to the addresses indicated for the different
channels used to access the site;b) the voluntary filling in of forms present in various sections of the website.

Obligation or right to provide data and consequences of refusal
The provision of "mandatory" personal data (marked with an asterisk) is necessary for
Farmindustria to meet the user’s needs in the functioning of the website.
Refusal, partial or inaccurate provision of the above mandatory personal data will makeexecution of the requested service impossible.
Failure, partial or inaccurate provision of optional data (not marked with an asterisk) will
not entail any consequences for the data subject (site user/visitor).
Personal data will be processed in a predominantly automated form, or manually on paper,on the basis of a logic strictly related to the aforementioned purposes and for the timestrictly necessary to achieve these purposes and in any case through the use of tools
appropriate for guaranteeing the security and confidentiality of the data, and in accordancewith the relevant regulations in force on the matter.
Cookies
The use of session cookies that are not stored persistently on the user’s computer anddisappear when the browser is closed is strictly limited to the transmission of session
identifiers, consisting of random numbers generated by the server, necessary to allow safeand efficient exploration of the website (so-called technical session cookies).
Disclosure and dissemination of personal data
Personal data provided directly by users by filling in online forms will not be "disseminated",
meaning that the data will not be provided to unidentified parties in any way, even by making
them available or permitting the consultation.
Personal data may, on the other hand, be "disclosed", meaning that knowledge of the data
may be provided to one or more specific persons: a) persons appointed within
Farmindustria to process the data, who will process same on the basis of the operating
instructions defined by Farmindustria as Data Controller; b) persons who can access thedata under the law, or under EU legislation, within the limits set forth by law; c) persons whoneed to access the data for purposes ancillary to the relationship with the user, within thelimits strictly necessary to carry out the auxiliary tasks entrusted to them (e.g. companies
and/or third parties whose services the Association makes use of in specific consulting anddata processing services), subject to a specific letter of appointment that imposes on suchthird parties the duty of confidentiality and security in data processing.
It should be noted that a complete, updated list of the third parties referred to in letter c)above, to whom the data may be disclosed in view of their capacity as Personal Data
Processors, may be requested by emailing privacy@farmindustria.it.

Data subjects’ rights
Pursuant to Articles 15 to 20 of the GDPR, data subjects (users/visitors) are entitled toexercise the following rights:• the right to obtain confirmation of the existence or non-existence of processing of theirdata, and access to their data, including information concerning:- the purpose of the processing;- the categories of personal data being processed;- the recipients to whom the data is or will be disclosed;- whether the data will be transferred outside the European Union, and the existence of thecorresponding guarantees;- the data retention period, or the criterion for determining it;- the source of the data, if the data has not been collected directly from the data subject;- the existence of an automated decision-making process.
• the right to obtain updating, correction and integration of their data;• the right to obtain erasure, transformation into anonymous form, or freezing of data which
need not be retained for the purposes for which the data was collected and processed;• the right to obtain a copy of the personal data being processed, in a structured format incommon use readable with an electronic device, also for the purpose of transmission toanother data controller, where this is not damaging to the rights and freedoms of others;• the right to revoke the consent provided at any time if the legal basis for the processing
consists of the data subject’s explicit consent;
Pursuant to Articles 21 and 22 of the GDPR, moreover, data subjects are entitled:• to object at any time, for legitimate reasons related to their situation, to the processingof data concerning them that is necessary for the performance of tasks in the public
interest or for the pursuit of the legitimate interests of the data controller;• not to be subjected to decisions based solely on automated processing, which may havelegal effects or a significant impact on the person of the data subject involved.
In any case, pursuant to art. 77 of the GDPR, the data subject is always entitled to lodge acomplaint with the Italian Data Protection Authority , if he or she considers the processingof his or her data to violate the laws in force concerning the protection of personal data.
To exercise their rights, or to obtain information regarding the processing of data concerningthem, data subjects may contact Farmindustria in one of the following ways:• through the postal service, by writing to the following address:
Farmindustria, Largo del Nazareno, 3, Rome;• by email sent to the following email address: privacy@farmindustria.it

In particular, the data subject may object at any time pursuant to art.21 of the GDPR - tothe sending of communications concerning the promotional activities and initiatives of theAssociation (for example: newsletters, memoranda, invitations, communications, etc.), bysending an e-mail to the address privacy@farmindustria.it.
Data Controller
The Data Controller is Farmindustria, the Italian Association of Pharmaceutical
Companies, a trade and professional organisation based in Largo del Nazareno, 3, Rome.
Retention of personal data
The data will be kept for the amount of time necessary to achieve the specific purposes forwhich the data is being processed and for the purposes of maintaining the membership
relationship.
Data acquired and used for promotional/informative purposes (sending of newsletters,invitations, memoranda and communications, etc.) will be processed until the user/data
subject objects to its processing and/or submits an explicit request for deletion of the data.
Transfer of personal data abroad
No provision is made for the dissemination and transfer of data outside the Economic Areaof the European Union, and consequently to a Third Country.
In any case, if it should become necessary, also for any needs pertaining to themanagement of cloud computing services (allocated on servers physically residing outside
the European Economic Area), the transfer of data abroad may be authorised, in thepresence of an assessment of adequacy conducted by the European Commission
pursuant to art. 45 of the EU Regulation, or, alternatively, after verifying the existence ofappropriate guarantees providing for enforceable rights and effective means of redress fordata subjects, referred to in art. 46 of the EU Regulation, by the Data Controller. In theabsence of any other assumption, it is possible to consider the transfer of personal data,
pending the existence of specific derogations pursuant to art. 49 of EU Regulation
2016/679.
Changes to this policy
Farmindustria reserves the right to modify or update the content of this privacy policy, inpart or completely, also in response to any changes to the applicable legal provisions. Suchchanges will become effective as soon as they are published on the Association's websites.
Farmindustria therefore invites you to visit this section regularly so as to be constantly
updated on the purposes and methods of processing, collection and use of data.

Social plug-ins and connections
The website may contain social network plug-ins. If you access a web page with a plug-inof this type (such as a "Share" button), the Internet browser will connect directly to thesocial network, and the plug-in will be displayed on the screen through connection with thebrowser. Before using such Plug-ins, the data subject is invited to consult the privacy policyof the social networks, present on their official pages.