• Because we understand and respect how important your privacy is to you, our privacy protection commitment starts with our four confidentiality-related values: respect, trust, damage prevention and compliance.
  • We only use and share the personal data provided online in the ways described earlier in this policy or in other privacy statements and notifications.
  • We use policies and technical and physical controls to restrict access to the personal data you provide to prevent it from being used incorrectly.
  • For further details, read our online privacy policy or contact us.

Vree Health Italia makes available online information and services, as well as company news, to help the evaluation of our work.

Respecting the privacy of your personal data is very important to us. Our websites and other online resources containing this privacy policy (hereinafter the “policy”) undertake to collect, manage and protect users’ personal data, in compliance with the law and this policy. This policy applies to the personal data (as defined below) collected by our online resources and media such as websites, apps for mobile devices, e-mail and other downloadable and online tools that are linked to this policy. The policy does not apply to the personal information collected by resources and media that are not online, unless in cases in which this personal data is consolidated with personal information gathered online by us or by others on our behalf. Furthermore, this policy does not apply to the online resources belonging to third parties for which our websites contain links, as we have no control over their contents or privacy practices.

As indicated in this policy, all references to “Vree”, “us”, “we” and “our” refer to Vree Health Italia s.r.l.

What is meant by “personal data” in this privacy policy?

For the purposes of this policy, the term “personal data” means any information relating to an identified or identifiable individual, including data that identify an individual or that can be used to identify, pinpoint, tract or contact an individual.

How do you collect personal data online?

We collect personal data online by means of websites and other online resources. In conjunction with other online service providers, we also provide online resources from which we may receive personal data regarding the users of these resources. These online partnerships are governed by agreements requiring adequate personal data protection. Individuals can access many parts of our websites and online resources without submitting any personal data. We collect personal data online in three different ways:

Information provided directly by the user: we collect personal data and other information that the user may enter in forms or data fields on our websites or online resources. These data can include, as non-limiting examples: contact details, such as your name, postal address, e-mail address, telephone number, user ID and password, date of birth, professional qualifications, experience, business, skills, preferences, hobbies and interests. We may also collect the data regarding your health that you provide when you answer our questions and our questionnaires or when using the online health tool downloads we provide. Some of our websites enable users to purchase services. These websites also collect data regarding credit cards, in order to process these orders.

Data from public sources or third parties: we will be able to collect personal data concerning the users that sign into our websites from public or third-party sources in order to check their professional credentials and identity. When clients use a credit card to place an order through our websites, we will check the validity of the credit card through financial or credit organisations. In some cases, we may complement our user databases with third-party information. Some of this information may be personal data, for example, changes to data regarding postal addresses.

Information collected from the computer or other electronic device belonging to the user: we will collect information on the computer or other electronic device belonging to the user, if he/she visits our websites and uses our online resources. This information may include the IP (Internet Protocol) address, the ISP (Internet Service Provider), the domain name, the type of browser, the date and time of the request and information provided by tracking technologies, such as cookies, pixel tags, shared local objects (Flash), the local memory, Etags and scripts. In the United States, if you leave one of our websites without having logged in as a user, we can use cookies together with third parties to send advertisements to your computer or other electronic devices, in order to remind you of our website that you visited previously. Read our cookie privacy policy for further information on cookies and how to control them. If you use a mobile device to access our websites and online resources or to download our apps or services for mobile devices, we may also collect information regarding the device, for example, its ID and type, as well as data regarding the use of the device and the websites and any other mobile device resources.

We may also appoint other companies to send email correspondence on our behalf or to insert advertisements in other websites. We do not control the tracking technologies used by these other companies. For further information on how to control tracking by external subjects, read our Cookie privacy policy.

Why do you collect, use and disclose personal data?

Generally speaking, we collect online personal data, where necessary, to allow individuals to log in and personalize some of our resources and online notifications, such as newsletters. We use the personal data collected online to provide products, services, functions and other resources requested by individuals; for example, educational literature and information regarding our work, and programs by e-mail, tools, quizzes, questionnaires and surveys. We will analyze the personal data collected online for the identification and provision of supplementary services and special offers that we believe could be of interest to you. We assess the use of certain online resources and notifications only using data that cannot be identified or pooled data. We may also use personal data to control compliance, access authorization and the security of our online resources.

Social media: online social media resources are interactive tools that usually make it possible to cooperate and share information with others. Examples of social media resources are social networks, forums, bulletin boards, blogs, Wiki pages and the usual functions used to share website content and tools with friends or workmates. We may collect personal data from users in order to allow them to use the online social media resources that we may offer at certain times. Furthermore, we may permit the use of social media resources in order to publish or share personal data with others. You should think very carefully about which information about yourself you share with others when using social media resources. We have prepared an additional circular regarding options concerning the collection, use and disclosure of personal data on our websites and other online resources that provide or use social media.

Processing on mobile devices: some of our websites and some online resources have been designed specifically for use on mobile devices. The mobile device versions of some of our websites may require access via the user account for the website. The information regarding the use of the mobile device version of the website will be linked to your user account. Some of our websites and online resources make it possible to download applications (apps), widgets or other tools that can be used on your mobile device or other processing device. Some of these apps can store information regarding your mobile device or other device. These apps can send personal data to us or to other subjects acting on our behalf, in order to allow you access to your user account or to allow us to record the way in which these tools are used, for example, how often they are used and the most popular features. Some of these apps may make it possible to send reports and other information by email from the app. We can use personal or unidentifiable data sent to us in order to improve these apps, to develop new instruments, to improve quality and for other purposes described in this policy or in other circulars.

Do you consolidate personal data?

In compliance with the purposes identified and the standards outlined in this policy and in other applicable privacy circulars, in certain cases we consolidate and use the personal data shared with us by individuals through a number of services and channels, such as the telephone, surveys, websites and other online resources and notifications, in order to improve the quality of the services we offer.

What options do I have concerning the ways in which my personal data is collected, used and disclosed?

There are four option categories. These include:

No personal data collection: you can avoid providing us with personal data by choosing not to enter any personal data in forms or data fields on our websites and by not using any of the customised services provided by our online resources. However, some of our online resources are only available for individuals who provide personal data or use the customised services.

Restrictions and options regarding use and disclosure for other purposes: some of our online resources may require your authorisation for use and disclosure of your personal data, in order to add you to our contact lists, allow you to be included in a list of social media resources and identify you and offer special deals and supplementary services that we believe you might find interesting. You may restrict the use of your personal data by selecting or deselecting the options provided when you enter the data or in the case of a future offer. You may also edit your disclosure preferences (for example, by deciding not to receive previously-requested notifications) by contacting us using the dedicated e-mail address.

Tracking restrictions and options: our online resources that use tracking technology such as cookies, in order to track your preferences and personal choices, allow you to decide whether to use these tracking technologies or whether to obtain supplementary services by selecting or deselecting the options chosen during registration or when personal data were entered in forms or data fields. Our online resources do not restrict the unidentifiable use of tracking technologies for individual users. Individual users can control the use of certain tracking technologies, such as cookies, using most Internet browsers. Some Internet browsers allow you to restrict or deactivate the use of cookies for individual websites. Some other browsers allow you to choose the cookie settings for all the websites visited. If you have any doubts regarding the use of cookie technology, read our cookie privacy policy for further information on cookies and how to control them.

If you no longer wish to be registered for advertising purposes, you may do so by following the options made available by:

For further information on how to deactivate tracking for certain web browsers and mobile devices, visit the website http://allaboutdnt.com/.

E-mail notifications: you may choose to receive optional emails and other notifications from us by registering or subscribing to these notifications on our websites and other online resources. If you do not wish to receive optional notifications by e-mail, you may unsubscribe by visiting the website and the other online resources where you have registered, where available and update your e-mail notification options. Alternatively, you may follow the instructions on how to cancel registration or unsubscribe from e-mail notifications from us. You may also unsubscribe by writing to us using the dedicated e-mail address. If you do not wish to send us confirmation that you have read some of the e-mail notifications from us, you may stop the tracking of this type of notification by deselecting the receipt of e-mail notifications in one of the ways described above. In some cases, it will not be possible to disable e-mail tracking and we will continue sending you notifications.

If you decide to recommend one of our websites or online resources using the e-mail recommendation function, we will provide you with simultaneous information on the use of personal data by these features. E-mail suggestion functions do not usually save the names and e-mail addresses of the individuals to whom you send the links to our websites or our online resources.

Who will have access to my personal data?

Your personal data will be accessible to Vree Health Italia and to the individuals and organisations that use the personal data exclusively for us and under our supervision. The use and disclosure of personal data by external organisations and subjects acting on our behalf are governed by agreements requiring adequate personal data privacy. The personal data concerning you will be used and disseminated only by us and by the individuals and organisations working on our behalf, in line with this policy, other applicable privacy notifications and when explicitly authorised or required by applicable law, standards and rules.

Do you share personal data with third parties?

We do not usually sell on or share your personal data except in those cases described in this policy and other applicable privacy notifications; however, circumstances may occur in which we may, for corporate reasons, decide to reorganise or transfer our business by sale, merger or acquisition. Under these circumstances, the personal data may be shared with current or future buyers. We will obtain written assurance that the personal data will be adequately protected in these circumstances. We reserve the right to disclose your personal data, including your e-mail address, for purposes regarding government authorities, to the parties to pertinent legal proceedings, when authorised by the competent court and, otherwise only insofar as is required or explicitly authorised by applicable law. Your personal data shall not be shared in any other way without your authorisation.

How do you protect personal data?

We adopt reasonable procedures to protect personal data, depending on their sensitive nature, when they are collected and transmitted between your computer or device and our resources or our online servers, in addition to protecting the personal data in our possession against unauthorised access and dissemination, alteration or destruction. You are under obligation to protect your personal copies of the passwords and associated access codes for our online resources.

How do you protect the privacy of minors?

Our websites and online resources do not usually address children and most of the online services we offer are designed for individuals who are at least 18 years of age. When queries regarding a medicinal product are permitted by law, individuals who ask for information on a medicinal product indicated for use in children must be at least 18 years old.

We do not consciously collect personal data from children younger than 13 years of age. If you are parents or guardians and are aware that we have collected information from a minor, please contact our privacy office to ask for the minor’s data to be removed.

Occasionally, some of our websites and other online resources may provide special functions for minors. When we offer these features, we adopt appropriate procedures in order to guarantee that before the collection, use or dissemination of the personal data of a minor, verifiable consent has been obtained from a parent or guardian.

How can I access and correct my personal data?

In order to gain access to the personal data regarding you collected online and keep them correct, complete and up-to-date, or to request their deletion, you can contact us using the appropriate address. In some cases, when a legal or regulatory obligations requires us to keep certain information or to continue managing a service you have requested to guarantee the observance of your preferences or for other necessary corporate purposes, we may not be able to delete certain specific data regarding you. When applicable, you may update your personal data even online, by modifying the information entered previously in forms or data fields in our websites. When permitted by the law or by our transnational privacy rules policy, your ability to access and correct your personal data will be restricted when access and correction prevent us from being able to comply with a legal or ethical obligation; inhibit our ability to investigate, take or defend court cases; have the consequence of disseminating personal data regarding a third party; cause the breach of a contract or the dissemination of commercial secrets or other proprietary corporate information belonging to us or a third party.

How long do you keep personal data?

We usually keep personal data for as long as is reasonably necessary for the specific corporate purposes for which they were collected and for the period of use of our websites, apps and other online tools by you. In some cases, we may be under obligation to store them for longer periods pursuant to laws and regulations applying to our corporate business, including applicable regulations concerning restriction statements or for other necessary corporate purposes. Where possible, we aim to anonymise data or remove any unnecessary identifying information from the record that we may have to keep for longer than the original storage period.

What is our contact address for any privacy-related questions?

If you have any questions regarding this policy or our data collection, use and disclosure practices, you may contact the Vree privacy office by e-mail. When contacting us, make a note of the website or online resource used or that you provided with personal data, as well as the nature of the information entered. We will do our best to answer within 20 working days any requests, questions or concerns regarding access to personal data concerning you and collected online and our use of such personal data.

We might contact you to obtain follow-up information and share your question with other individuals inside our company or who are working on our behalf and are responsible for functions associated with the purpose of your question. With the exception of those cases in which it is required by law, we cannot guarantee an answer to questions or comments regarding topics not associated with this policy or our privacy protection policy.

How can I find out about any updates to this policy?

We may update this policy from time to time. We reserve the right to alter, add or remove parts of this privacy policy at our discretion. Should we decide to amend this policy, we will publish these changes on the website. In this way, you will always know which information we are collecting, how we can use the data and whether to disseminate them to others. If substantial changes are made to the policy, we may also publish a notification on the webpage www.vree.it/privacy before the amendment validity date or, in certain cases, we may provide notification concerning the amendment by e-mail. The most recent amendment of this policy was introduced on 30 April 2018.