Interactions with healthcare professionals (HCP's) and commercial contacts
Privacy notice available in other languages.
Grifols is a global healthcare group founded in Barcelona in 1909 committed to improving the health and wellbeing of people around the world. Its three main business units – Biopharma, Diagnostic and Bio Supplies – develop, produce and market innovative solutions and services that are sold in more than 100 countries.
Grifols respects the privacy rights of all data subjects who entrust Grifols with their personal data and is committed to complying with the data protection regulations applicable in each country.
This privacy notice has been prepared in accordance with the European Union General Data Protection Regulation (the "GDPR") and applicable privacy and data protection laws; see Section 7 for specific provisions. It outlines Grifols' data collection practices and the choices that data subjects have about the way Grifols collects, uses and shares their personal data.
This privacy notice applies to the processing of personal data of (a) healthcare professionals, commercial contacts and individuals belonging to institutions to whom Grifols provides, or could potentially provide services and/or products, and (b) healthcare professionals or commercial contacts that collaborate or could potentially collaborate with Grifols directly or indirectly. For the purpose of this privacy notice, "data subject" refers to both types of individuals.
1. Identification of the data controller(s)/owner(s) of the personal data
The data controller(s)/owner(s) is/are:
- The Grifols' group company with which the data subjects (as defined above) have a contractual relationship,
- The Grifols' group company operating and identified as such in the websites, landing pages, apps, and any other similar digital platforms through which the personal data of the data subjects are processed,
- The Grifols' group company contacting or to whom the data subjects may contact (as identified in the methods used to establish said contact) for the remaining purposes set out in Section 3, or
- Grifols Viajes, S.A. for all activities relating to the management of travel and events.
When the processing of personal data has a scientific purpose, the data controllers/owners of the personal data will jointly be the company identified in Section 1(a), (b) or (c) and Grifols, S.A.
The identity and contact details of the Grifols' group companies are available here. The Grifols' group company/ies acting as controller/s or joint controllers will be referred to as "Grifols".
2. Identification of the data protection officer
The data protection officer acts as an interlocutor between Grifols and you in order to ensure Grifols' compliance with the data protection legislation and to guarantee your rights under such legislation. You may contact the data protection officer at dpo@grifols.com, unless the data controllers are Grifols Deutschland GmbH or Haema AG, in which case you may contact the data protection officer of each of these companies at dsb@grifols.com and dsb@haema.com, respectively.
Although the essential aspects of the joint controllership agreement resulting from what is set out in Section 1 are provided in this Privacy Notice, the data subjects may ask, if they wish so, the data protection officer for more information.
3. Purposes, lawful basis for processing, categories and recipients of personal data
Purposes | Categories of personal data and recipients | Lawful basis |
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Categories of personal data:
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Legitimate interest |
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Categories of personal data:
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Legitimate interest |
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Categories of personal data:
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Legitimate interest |
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Categories of personal data:
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Legitimate interest |
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Categories of personal data:
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Legitimate interest |
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Categories of personal data:
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Legitimate interest |
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Categories of personal data:
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Consent |
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Categories of personal data:
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Consent |
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Categories of personal data:
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Consent |
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Categories of personal data:
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Consent |
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Categories of personal data:
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Consent |
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Categories of personal data:
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Consent |
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Categories of personal data:
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Legal obligation |
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Categories of personal data:
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Legal obligation |
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Categories of personal data:
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Legal obligation |
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Categories of personal data:
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Execution of a contract |
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Categories of personal data:
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Execution of a contract Legitimate Interest |
1. For example, name, last name, sex, nationality, image, voice, number of national/foreigner's ID/passport document, social security affiliation number, username. 2. For example, professional contact details, job position, place of work, member of professional associations. 3. For example, financial interests and bank details. 4. For example, IP address, device or user ID, browser type and version, visited sections, country from which the connexion is made. 5 For example, training, degree, curriculum vitae. |
3.1. Additional information about the lawful basis to process personal data
The table above shows the applicable lawful basis to process the personal data by purpose. In this section, you can find additional details of the lawfulness of the processing:
- Consent (article 6.1(a) of the GDPR): Data subjects may provide their consent through the data collection forms, by clicking acceptance buttons or ticking boxes, replying to e-mails or making any other affirmative clear action. Data subjects may withdraw their consent at any time, as set out in Section 6.
- Execution of a contract (article 6.1(b) of GDPR): Failure to provide the personal data requested by Grifols could result in the impossibility of executing or maintaining such contract.
- Legitimate interest of Grifols and/or third parties (article 6.1(f) of GDPR): Grifols is interested in contributing to the advancement of scientific knowledge and research in a secure environment with the aim of guaranteeing people's health. Therefore, Grifols pursues the following legitimate interests which override the fundamental rights and freedoms of the data subjects, given that the processing is within the data subjects' reasonable expectations based on their relationship with Grifols:
- Prevention of fraud,
- Direct marketing
- Daily management of a multinational group of companies and internal administration, which means sharing information with the companies of the Grifols group, and
- Creation of a secure information system infrastructure for preventing unlawful or malicious activities that may compromise the personal data.
In any event, data subjects may request further information on the legitimate interest or exercise their right to object to the processing of their personal data based on legitimate interest by addressing their request to privacy@grifols.com.
- Legal obligation (article 6.1(c) of GDPR): Grifols needs to process the requested personal data to comply with legal obligations. Failure to provide the personal data requested could result in the impossibility for Grifols to comply with such legal obligations. Section 7 includes details of the specific regulations applicable to Grifols that require the processing of personal data.
3.2. Recipients of personal data
The table above shows categories of recipients with whom Grifols may share personal data by purpose. This section includes additional information regarding these recipients when applicable:
- Grifols' group of companies: The list is available here.
- Distributors of companies of the Grifols' group and other commercial contacts: for example, agents and any other commercial contact who can help Grifols evaluate business opportunities.
- Providers of products and services: for example, travel agencies, transport companies, IT service providers, credit risk service providers, clinical studies service providers, insurance providers, courier agencies, marketing agencies, event organizers, providers operating in the anticorruption sector, lawyers, auditors, photographers, cameramen and media agencies/owners.
Grifols' website may include social network plugins, which can be recognised by the social network's logo or name, so that users can access Grifols' profile on these platforms. By clicking these buttons, users' personal data (including, IP address and browsing data) will be transferred to the providers of said social networks. Grifols will not be liable for any further processing theta the providers of the social networks may carry out with this personal data. The purpose and scope of the collection of data and its subsequent processing and use by the providers of these social networks, as well as the related rights and the possibilities of configuring privacy settings can be consulted in the data protection information of each of these companies.
- Public or private organizations: for example, health authorities, pharmaceutical industry associations or governmental organizations.
- Potential investors or purchasers
- Financial entities
Grifols will endeavour that the personal data is only transferred to countries that offer an adequate level of data protection. If the personal data is processed in countries that do not offer said level of protection, Grifols and/or the providers (as the case may be) will adopt, if necessary, the appropriate safeguards (e.g. the standard contractual clauses included in the Commission Implementing Decision (EU) 2021/914 of 4 June 2021, if GDPR is applicable) to carry out such international data transfers in accordance with the applicable data protection legislation. Specific information on the appropriate safeguards applicable to each international data transfer can be obtained from Grifols at privacy@grifols.com.
Grifols does not share personal data with any other third party unless it is authorized by the data subject or required by the applicable law.
4. Retention period
Grifols will retain the personal data for the time strictly necessary for the fulfilment of the purposes for which it has been collected or, if applicable, until the end of the statutes of limitation of any liabilities that may arise, and during the term required to comply with any applicable legal obligation.
5. Sources of personal data
If data subjects do not directly provide Grifols with their personal data, Grifols may obtain the personal data from event organizers databases and public sources, such as websites and publications from the healthcare sector, professional social networks or social listening tools (that is, tools aimed at identifying and evaluating the market's perception about a specific brand, product, company, topic or problem).
If data subjects provide personal data of third persons for the purpose of executing and maintaining a contractual relationship, the data subjects will inform said third persons about the processing of their personal data beforehand, by providing a copy of this privacy notice.
6. Data protection rights
The following data protection rights are applicable under the GDPR. Grifols undertakes to respect other data protection rights that may be applicable in accordance with the data protection legislation of each country.
Rights | Content |
Access | You may request confirmation as to whether or not your personal data is being processed and, if so, you can obtain access to your personal data included in Grifols' files. |
Rectification | You may request the rectification of your personal data if inaccurate. |
Erasure | You may request the erasure of your personal data. |
Objection | You may request that your personal data is not processed under specific circumstances. |
Portability | You may request receiving, in an electronic file, the personal data that you provided Grifols with, as well as the right to transmit it to other parties. |
Restriction of processing | You may request a restriction on how your personal data is processed when:
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Withdrawal of consent | You may withdraw your consent without affecting the lawfulness of the processing based on consent before its withdrawal. |
You may exercise, when appropriate, your data protection rights by, for example, sending a written communication to Grifols at privacy@grifols.com with the subject line "Interactions with HCP’S and Commercial Contacts". To that end, Grifols may request further information or documents if necessary to identify you.
For residents in the United States, please contact the Privacy Office at US-PrivacyRights@Grifols.com.
In addition, you may lodge a complaint with a data protection authority, including the one at your residence, place of work or place of the alleged infringement.
7. Specific Provisions
- European Union
The legal obligation referred to in Section 3 with respect to the response to medical and technical (non-commercial) requests for information about products manufactured or distributed by Grifols is regulated in Directive 2001/83/EC of the European Parliament and of the Council of 6 November 2001 on the community code relating to medicinal products for human use and any other applicable regulations implementing, developing, complement and replacing the aforementioned. - France
When Grifols France S.A.R.L. is the data controller, the data subjects have the right to provide guidance on the management of their data after their death.
The legal obligation referred to in Section 3 to publish the transfers of value made to the data subjects and to share said personal data with the health authorities or associations of the pharmaceutical industry is regulated in the French public health code and in any other law that develops, complements and/or replaces it. - People’s Republic of China
- Mainland China: When your personal data is being processed by any Grifols' group company in mainland of the People’s Republic of China, the addendum available here applies to you. The addendum is set out in addition to and forms an integral part of this privacy notice.
- Portugal
When Grifols Portugal – Produtos Farmacêuticos e Hospitalares, Lda. is the data controller, the data subjects have the right to provide guidance on the management of their data after their death. When guidance on the management of their data has not been provided by the deceased data subjects, the exercise of the data protection rights defined in Section 6 may be carried out by their heirs. The data subjects may also determine the impossibility of exercising these rights after their death.
When there is a legal obligation of secrecy, the rights of the data subjects cannot be exercised.
The legal obligation referred to in Section 3 to publish the transfers of value made to the data subjects and to share said personal data with the health authorities or associations of the pharmaceutical industry in order to ensure greater transparency in the interactions held among the distinct market players is regulated in the Medicinal Product Statue (Decree Law 176/2006), in the Medical Devices Regime (Decree-Law 145/2009) and in any other laws that develop, complement and/or replace these. - Thailand
When Grifols (Thailand) Ltd. is the data controller, see full privacy notice here. - United Kingdom
All references throughout the document to the GDPR also refer to, as applicable, the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland. - United States
You can review the privacy notice here
Last update: March 2023
****This is a translation from the original in Spanish. In case of discrepancy, the Spanish version will prevail.****
Privacy notice available in other languages
CS – Prohlášení o ochraně soukromí – Vztahy se zdravotníky a obchodními kontakty
EN – Privacy notice - Interactions with healthcare professionals and commercial contacts
FR – Notice d'information – Relations avec les professionnels de la santé et contacts commerciaux
IT – Informativa sulla privacy – Intereazioni con professionisti sanitari e contatti commerciali
PL – Polityka prywatności – Relacje ze specjalistami ochrony zdrowia i kontakty
PT – Aviso de privacidade - Interações com profissionais de saúde e contatos comerciais