Privacy Policy - ADIENNE - Pharma & Biotech

Privacy Policy for Customers

Dear Customer,
pursuant to EU Regulation 2016/679 (“GDPR”) and the current Swiss privacy legislation, the Companies of the ADIENNE Group (hereinafter “ADIENNE”) as Data Controllers (or joint Data Controllers), wish to inform you about the personal data you provide to ADIENNE.

• Category of data processed

Personal identification data (e.g. name, surname, business address), contact details (e.g. landline/mobile phone number, e-mail address/certified e-mail address), image data (e.g. photograph on identification document, audio video recordings, etc.).

• Purpose of Processing and Legal Basis for Processing

The personal data you provide are processed, until you object, in order to:
– respond to questions regarding our pharmaceutical products, our services, our activities;
– respond to specific questions relating to marketed products (such as, for example, order tracking, complaints, returns, pharmacovigilance, med-info, etc.) or products under development;
– present products and conduct promotional campaigns in compliance with applicable current legislation;
– fulfil the contractual obligations undertaken;
– protect our rights in court;
– ensure the application of the ADIENNE Code of Ethics.

The legal basis for processing is Art. 6, paragraph 1, letter f) of recital 47 and is based on the legitimate interest and right of ADIENNE to provide its customers with the necessary information as well as in the need to comply with legal obligations.

For the purposes of this Policy, “processing” means all the following operations: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, erasure and destruction of data.

The provision of your common personal data is necessary to the extent that we need such data to provide you with the necessary information, products and services described above. Failure to provide the same may prevent ADIENNE from fulfilling the requests made and/or the contractual obligations undertaken.

• Methods of processing and storage

The data you provide will be processed in automated and/or manual form, with methods and tools designed to ensure maximum security and confidentiality, in order to prevent data loss, illegitimate or unlawful use of data and unauthorized access to the same. The data will only be processed by persons expressly authorized to do so. Personal data is stored on servers located in secure and controlled access locations. The data will be stored for an appropriate period to be determined in accordance with the purposes of processing and the applicable legislation in force. After this period, the data will be duly destroyed.

• Communication and dissemination

The data may be made accessible for the purposes indicated above to the employees of the Data Controller (or joint Data Controller), as authorized data processors, to internal or external data processors, to affiliated companies, to third parties contractually linked to ADIENNE where they have a legitimate need to receive the data (e.g. consultants, business partners) and to the competent authorities to comply with legal obligations or measures issued. Your data will not be subject to fully automated decision-making processes, including profiling.

• Data transfer

The data may be transferred to non-EU countries for the purposes indicated above, but always in compliance with the provisions of the GDPR and the applicable privacy legislation.

• Rights of Data Subjects

Pursuant to Articles 15 to 22 of the GDPR, you may exercise the right to:
‐ request confirmation of the existence or otherwise of your personal data;
‐ obtain information about the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data have been or will be disclosed and, where possible, the retention period;
‐ obtain the rectification and erasure of data;
‐ obtain the restriction of processing;
‐ obtain data portability, i.e. receive the data from a data controller, in a structured, commonly used and machine-readable format, and transmit the same to another data controller without hindrance;
‐ object to processing at any time, including for direct marketing purposes;
‐ object to automated decision-making relating to natural persons, including profiling;
‐ request from the data controller access to your personal data and the rectification or erasure of the same or the limitation of processing or to object to processing, as well as the right to data portability;
‐ withdraw consent at any time without prejudice to the lawfulness of the processing based on the consent given prior to withdrawal;
‐ lodge a complaint with a supervisory authority.

You may exercise your rights by sending a written request to the registered office of the Group companies with which you have a contractual relationship or to the dedicated e-mail address indicated below:

ADIENNE Pharma & Biotech SA, Via Zurigo 46 6900 Lugano (CH): privacyadiennephab@adienne.com
ADIENNE SA Via Zurigo 46, 6900 Lugano (CH): privacyadiennesa@adienne.com
ADIENNE SRL Via G. Galilei 19, 20867 Caponago (MB) Italy: privacy@adienne.com

Text Last Revised: 7.1.2025

Privacy Policy for Suppliers

Dear Supplier,
pursuant to EU Regulation 2016/679 (“GDPR”) and the current Swiss privacy legislation, the Companies of the ADIENNE Group (hereinafter “ADIENNE”) as Data Controllers (or joint Data Controllers), wish to inform you about the personal data you provide to ADIENNE.

• Category of data processed

• Purpose of Processing and Legal Basis for Processing

The personal data you provide are processed, until you object, for purposes related to (i) your contractual relationship, including the pre-contractual phase (including any due diligence checks), negotiation, stipulation and execution of the same; (ii) compliance with specific legal obligations; (c) the verification by ADIENNE, of Suppliers’ compliance with the rules of conduct contained in the Code of Ethics adopted by ADIENNE; d) legal and judicial defence.

The legal bases of the processing for the aforementioned purposes are Art. 6(1)(b); 6(1)(c) and 6(1)(f) of the GDPR respectively. The provision of personal data for the purposes indicated above is optional, but failure to do so will make it impossible to establish contractual or pre-contractual relationships with ADIENNE.

• Methods of processing and storage

The data you provide will be processed in automated and/or manual form, with methods and tools designed to ensure maximum security and confidentiality, in order to prevent data loss, illegitimate or unlawful use of data and unauthorized access to the same. The data will only be processed by persons expressly authorized to do so. Personal data is stored on servers located in secure and controlled access locations. The data will be stored for an appropriate period to be determined in accordance with the purposes of processing and the applicable legislation in force. The Data Controller may retain some data even after the termination of the contractual relationship, for the time necessary to fulfil contractual and legal obligations or for judicial protection purposes. After this period, the data will be duly destroyed.

• Communication and dissemination

The data may be made accessible for the purposes indicated above to the employees of the Data Controller (or joint Data Controller) in their capacity as authorized data processors, to internal or external data processors, to affiliated companies, to third parties contractually linked to ADIENNE where they have a legitimate need to receive the data (e.g. consultants, business partners), to third parties in the event of mergers, acquisitions, company or business unit transfers, audits or other extraordinary transactions to the competent authorities and to the competent bodies and institutions to comply with legal obligations or measures issued. Your data will not be subject to fully automated decision-making processes, including profiling.

• Data transfer

The data may be transferred to EU and non-EU countries for the purposes indicated above, but always in compliance with the provisions of the GDPR and the applicable privacy legislation.

• Rights of Data Subjects

Pursuant to Articles 15 to 22 of the GDPR, you may exercise the right to:
‐ request confirmation of the existence or otherwise of your personal data;
‐ obtain information about the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data have been or will be disclosed and, where possible, the retention period;
‐ obtain the rectification and erasure of data;
‐ obtain the restriction of processing;
‐ obtain data portability, i.e. receive the data from a data controller, in a structured, commonly used and machine-readable format, and transmit the same to another data controller without hindrance;
‐ object to processing at any time, including for direct marketing purposes;
‐ object to automated decision-making relating to natural persons, including profiling;
‐ request from the data controller access to your personal data and the rectification or erasure of the same or the limitation of processing, or to object to processing, as well as the right to data portability;
‐ withdraw consent at any time without prejudice to the lawfulness of the processing based on the consent given prior to withdrawal;
‐ lodge a complaint with a supervisory authority.

You may exercise your rights by sending a written request to the registered office of the Group companies with which you have a contractual relationship or to the dedicated email address indicated below:

ADIENNE Pharma & Biotech SA, Via Zurigo 46, 6900 Lugano (CH): privacyadiennephab@adienne.com
ADIENNE SA Via Zurigo 46 6900 Lugano (CH): privacyadiennesa@adienne.com
ADIENNE SRL Via G. Galilei 19, 20867 Caponago (MB) Italy: privacy@adienne.com

Text Last Revised: 7.1.2025