Privacy Policy

This privacy notice (the “Notice”) explains how Pharma Complete Solutions Limited, a company incorporated under the laws of England and Wales with company number 15921489, and having its registered office at Donington Court, Herald Way, Castle Donington, Derby, England, DE74 2UZ, (referred to as the “Group”, “Company”, “Organisation”, “we”, or “us”), collects and processes personal data.

It applies to information relating to our customers or potential customers who provide personal data via our website pharmacompletesolutions.com, the PCS Self-Service Center, our mobile applications, and any other system application or digital platform we operate (together referred to as "our systems"). Such personal data may be provided by individuals directly, or by representatives, employees, or contact persons of legal entities.

Please notice that our systems are powered by Awery Software FZ-LLC.

This Privacy Policy explains how we process information that is provided to us or collected through our systems where this Privacy Policy is displayed. It applies to all users of our services.

Any personal information collected through our systems is subject to the terms of this Privacy Policy.

If you choose to provide personal data to Pharma Complete Solutions Limited, please note that you are not legally obligated to do so and that such information is provided voluntarily. By submitting your personal data, you expressly acknowledge and agree to the terms of this Notice, and you consent to our collection, use, and sharing of your personal data with third parties in accordance with the provisions of this Privacy Policy.

Please be aware that failure to provide certain requested personal data may limit or prevent us from delivering our products and/or services to you.

Pharma Complete Solutions Ltd acts as the Data Controller for all personal data collected and processed in connection with the provision of our services.

To deliver our services and manage the technical operation of our systems, we engage trusted third-party service providers, in this case Awery Software FZ-LLC (Data Processor), who process personal data solely on our documented instructions and in compliance with applicable data protection laws.

In particular, Awery Software FZ-LLC provides the software infrastructure and hosting services through which certain personal data is stored and managed. Awery Software FZ-LLC processes such data exclusively on our behalf, implementing appropriate technical and organisational measures to ensure the security, confidentiality, and integrity of the personal data.

For further information about our data processors, or to exercise your rights under applicable data protection laws, please contact us at pharma@pharmacompletesolutions.com

Personal Information

We may collect and process personal information about you, such as:

• Identity Data includes first name, maiden name, last name, username or similar identifier, title.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our systems.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use, and share aggregated data, such as statistical or demographic information, for any purpose. Aggregated data may be derived from your personal data; however, under applicable law, it is not considered personal data if it does not directly or indirectly identify you.

For example, we may aggregate your usage data to calculate the percentage of users who access a specific website feature. If, however, we combine or link aggregated data with your personal data in a way that could directly or indirectly identify you, we will treat the combined data as personal data and handle it in accordance with this Privacy Policy.

We do not collect any special categories of personal data about you. This includes information regarding your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, genetic data, or biometric data. We also do not collect any information about criminal convictions or offences.

If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We rely on consent to be obtained from the data controller to process your personal data. If there are questions surrounding how this consent is obtained and maintained, or any questions surrounding how consent can be withdrawn, please contact the applicable data controller.

We make every effort to ensure that our privacy practices are transparent and understandable.

By using our services, you acknowledge that you have read and understand this Privacy Policy.

We collect information you provide for the following purposes:

• Service Delivery: We use your personal information to provide you with the products or services you have requested. This may include processing your payment, shipping products to your address or providing access to our online services. The lawful basis for this processing is typically the performance of a contract because we need to process your data to fulfil our contractual obligations to you.
• Communication: We may use your contact information to communicate with you. This includes sending transactional emails, service updates, and responding to your inquiries or requests. We may also use your contact information for marketing purposes, such as sending newsletters or promotional offers if you have provided your consent or if we have a legitimate interest in doing so. The lawful basis for processing personal information for communication is legitimate interests and, when applicable, consent if you have provided it.
• Account Management: We use your personal information to manage your account, including account setup, verification, and maintenance. This ensures the security and functionality of your account on our platform. The lawful basis for this processing is typically the performance of a contract to maintain your account.
• Customer Support: Your information allows us to provide customer support when you have questions or encounter issues with our products or services. This may include troubleshooting, resolving complaints, and addressing your concerns. This processing is based on the legitimate interests to assist you in using our services effectively.
• Improvement of Services: We analyze your data to understand how our services are used and to make improvements. This includes enhancing the user experience, developing new features, and optimizing the performance and security of our products. This processing is also based on legitimate interests to improve and maintain the quality of our services.
• Legal Compliance: We may process your personal information to comply with our legal obligations, such as tax reporting, responding to legal requests, or assisting law enforcement agencies when required by law. This processing is necessary to fulfil legal obligations.
• Contractual Obligations: If you are a client or business partner, we may use your personal information to fulfil our contractual obligations, including managing contracts, invoicing, and providing support as agreed upon in our business relationship. The lawful basis for this processing is the performance of a contract.
• Fraud Prevention and Security: We use your information to protect against fraud, unauthorized access, and other security risks. This may include monitoring account activities and implementing security measures. The lawful basis for this processing is legitimate interests to ensure the security and integrity of our services.
• Aggregated and Anonymized Data: We may aggregate and anonymize your data to create statistical or research reports, which do not personally identify you. This information may be used for business analysis, marketing, and sharing with partners or clients. The lawful basis for processing aggregated and anonymized data is legitimate interests and the fact that this data is no longer considered personal information.
• Other Purposes: In addition to the purposes listed above, we may use your personal information for other legitimate purposes, provided that they are compatible with the original reasons for which your data was collected. For these other purposes, we will rely on legitimate interests or other lawful bases as required by applicable laws.

We may share your personal data as follows:

• Internally, limiting access to what is required or needed by individuals to perform their role.
• Entities, subsidiaries and affiliates forming part of the Group on an “intra-group” basis.
• Professional advisors, third party service providers, including clouds, software and database providers, agents, or independent contractors providing services to the Company.
• Authorities, law enforcement bodies, courts, where such disclosures are permitted or required pursuant to applicable law.
• Business partners or potential business partners, inter alia within reorganization, transfer and/or sale and/or assignment and/or acquisition of the Company and/or its assets and/or any part thereof, for consideration or without consideration, to third parties, including but not limited to a case of merger of the Company and/or its activity with third parties, in cases of full or partial change of control of the company and for examining the feasibility of the events mentioned above.
• With Your Consent: We may share your personal information with third parties if you have provided your explicit consent for such sharing. We will always request your consent before sharing your data for specific purposes.
• Other Legitimate Business Interests: In certain cases, we may share personal information with other parties for legitimate business interests. The sharing of this personal information may be based on legitimate interests. We will always ensure that such sharing is conducted in accordance with applicable data protection laws and respect your rights.

As a global organization, we may transfer your personal data to countries outside the European Union (EU) or the European Economic Area (EEA). Such transfers may be necessary for the purposes outlined in this Privacy Policy, including providing you with requested products or services, communicating with you, and conducting our business operations effectively.

When we transfer your personal data to countries outside the EU/EEA, we will ensure adequate safeguards are in place to protect your personal data as required by applicable data protection laws and regulations. These safeguards may include (but are not limited to):

• Standard Contractual Clauses: We may use standard contractual clauses approved by the European Commission or other relevant data protection authorities to ensure the protection of your personal data during transfer.
• Binding Corporate Rules (BCRs): Where applicable, we may rely on BCRs adopted by our organization to ensure the protection of personal data transferred across borders within our corporate group.
• Data Protection Agreements: We may enter into agreements with recipients of your personal data outside the EU/EEA, imposing obligations on them to protect your personal data to the same standards required in the EU/EEA.
• Certification Mechanisms: We may rely on certification mechanisms such as the EU-U.S. Privacy Shield Framework, where applicable, to ensure that third-party recipients of your personal data provide an adequate level of protection.

By using our services or providing your personal data to us, you consent to the transfer of your personal data as described in this Privacy Policy. If you do not agree to such transfers, please refrain from using our services or providing your personal data to us.

If you have any questions or concerns regarding the transfer of your personal data outside of the EU/EEA or the safeguards we have implemented, please contact us using the contact details provided at the end of this Privacy Policy.

Under GDPR you have the following rights:

1. Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
2. Request rectification of Personal Data that we process about You.
3. Request erasure of your Personal Data (where applicable). This enables you to ask the Company to delete or remove personal information where there is no good reason for us continuing to process it.
4. Object to the processing of your Personal Data (where applicable) where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes You want to object to processing on this ground.
5. Request that we provide you with any personal data that you may have provided us, in a structured, commonly used and machine-readable format.
6. Request the restriction of processing of your personal information.
7. Request that we transmit your personal data directly to you or to another controller indicated by you.
8. Right to be informed of the source – where the personal data we hold about you was not provided to us directly by you, you may also have the right to be informed of the source from which your personal data originates.

The above rights are not absolute and can be subject to specific legal requirements or exemptions and therefore may not always be applicable.

There is no charge for the provision of the related information, following your request, except in circumstances where the request is manifestly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. The Company may withhold certain information which is exempt from the right of Subject Access in accordance with applicable Law.

We may need to request specific information from you to help us confirm your identity and ensure the exercise of your rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Although all reasonable efforts will be made to keep your information updated, you are requested to inform us of any change referring to the personal data we hold about you. In any case, if you consider that certain information about you is inaccurate, you may request rectification of such data, as explained above.

To exercise any of your rights, file a complaint relating to your privacy or if you have any other questions about our use of your personal data, please email
pharma@pharmacompletesolutions.com

You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

We implement and maintain reasonable technical and electronic safeguards to protect the security of your personal information.

While we implement these security measures to protect your data, it is important to understand that no online platform can guarantee absolute security and we cannot guarantee absolute security of your personal data.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or contractual requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, as well as applicable legal requirements.

Upon expiration of the applicable retention period, we will securely delete or anonymize your personal data in accordance with applicable laws and regulations.

We may use “cookies” (or similar tracking technology) on our systems.

Cookies are text files that our web server may play on your hard disk to store your preferences. When you visit our systems, you will be presented with a cookie banner or pop-up requesting your consent to use non-essential cookies. You have the right to accept or decline the use of such cookies. Your consent can be managed and changed at any time through your device or browser settings.

Cookies, by themselves, do not provide Awery or us with any PII unless you explicitly choose and consent to provide this information to Awery. Once you choose and consent to provide PII, however, this information may be linked to the data stored in the cookie. If you choose to turn off collection of cookies through your device or browser, certain features of our service may not function properly without the aid of cookies.

Our systems may also incorporate third-party cookies and tracking technologies. These technologies are subject to the privacy policies and practices of the respective third parties. We encourage you to review the privacy policies of these third parties for information on how they collect and use your personal data.

Our systems are intended solely for users who are 18 years of age or older.

By accessing or using our systems, you represent and warrant that you are at least 18 years old. If you are under 18 years of age, you are not permitted to access or use our systems under any circumstances.

We periodically review this Privacy Policy and may make updates. Your continued use of our systems following any notice of changes to this Privacy Policy means you accept such changes.

If you have any questions, concerns, or requests regarding your personal data or this Privacy Policy or for specific requests relating to your rights as a data subject including the rights noted in section “Data Subject Rights” noted above, please contact us at pharma@pharmacompletesolutions.com