Privacy Notice

This privacy notice covers our main website, www.thepharmanavigator.com. We describe here the data we collect from you when you use our site, together with the personal data we process when you subscribe to our newsletter, or contact us with a general enquiry.

These are our reasons for collecting it, what we do with it and what your rights are.

WHO ARE WE?

We are: Navigator Media Ltd., Fifth Floor Suite A2, Chester Steam Mill, Steam Mill Street, Chester, England, CH3 5AN. Company registration number 15251347.

You can write to us at the above address, email us at news@thepharmanavigator.com, or call us on +44 (0)1244 953 043.

We are the data controller for this processing and are registered with the UK Information Commissioner’s Office (ICO). Our registration number is ZB053730. We have appointed a Data Protection Officer (DPO) who can be contacted via paul@gdprassist.co.uk.

PURPOSE OF PROCESSING

Where we are the Data Controller we process your personal data for a variety of purposes as set out in the table below, which also shows our lawful basis under UK data protection legislation (UK GDPR) for doing so.

Where we are providing marketing support services to our clients we act as a Data Processor on their behalf.

Where we are relying on our legitimate interests you are free to object to that at any time.  In the case of direct marketing activities we will ensure that we cease to market our services to you should you object to our legitimate interests.

Where we are relying on your consent you are free to change your mind and withdraw your consent at any time.

DATA WE COLLECT

The table below gives information on the categories of personal data we process for each of the purposes shown above.

SPECIAL CATEGORY DATA

We do not routinely process any such special category data, however we may occasionally do so (for example when we manage an event you are attending we may ask for any dietary or access requirements which could include data relating to belief or health) and will always ensure we have a lawful basis (normally by asking for your explicit consent) and only retain the information for a very limited period of time.

HOW LONG DO WE KEEP YOUR DATA FOR?

Where we are relying on our legitimate interests to process your data then we will keep your personal data until you object to our legitimate interests and we agree with your objection, or until the following default periods have elapsed after our last contact with you. 

We will retain your personal data by default for the following periods:

DO WE EVER SHARE PERSONAL DATA?

We will share your data if required to do so by a legitimate law enforcement agency. 

When you submit your personal data online your data is held by our partner who hosts our website.

If you consent to the use of analytics and tracking cookies from our website we will share data with those cookie providers (see below).

If we are communicating with you via email or social media channels we will be sharing your personal data with those email and social media providers.

We also utilise external suppliers to provide business support services.  We always ensure that we have appropriate contracts in place to protect your rights when personal data are processed on our behalf by these third parties.  Please see the “Where Do We Process Data” section for more information.

We also share data between ourselves and Orientation Marketing LTD in the UK, and their , USA and Finland divisions to enable us to deliver our services.

HOW DO WE KEEP YOUR DATA SECURE?

We take sensible steps to keep your data secure:

  • All data sent between your browser and our website is encrypted in transit,

  • Our website is hosted in the UK, however personal data will be stored in the USA with appropriate protections (see “Where Do We Process Data” below),

  • We maintain appropriate records of processing activities which record any data processors we use and we ensure that appropriate contracts are in place to protect your rights, that the processors take appropriate security measures to safeguard your data, and that any international transfers are done correctly under UK data protection laws,

  • Our employees are all subject to an obligation of confidentiality, and receive training on data protection matters,

  • We ensure multi-factor authentication is enabled where available on any business support systems we use.

YOUR RIGHTS

You have a number of rights relating to the processing of your data, if you would like to use them or have any questions then please contact us.

We won’t charge you for doing any of the following, however we may make a charge in the case of frequent repeat or unfounded requests:

Awareness: You have the right to be fully informed about why and how we process your information.  This privacy notice is intended to meet that requirement, but please do contact us if you have any questions,

Access: You have the right to a copy of the data we hold about you

Rectification: If you think some of the data we hold is wrong then you have the right to ask us to correct it,

Erasure: You have the right to ask us to delete the data we hold about you, however we will need to retain the data in accordance with the data retention requirements shown below,

Restriction: You have the right to ask us to restrict the processing of personal data whilst we check its accuracy, if you think the processing is unlawful, if you believe we no longer need to process the data but you need us to store it due to pending legal claims, or when you object to our processing based upon our legitimate interests and we are assessing the validity of that,

Object: Where we are processing your personal data based upon our legitimate interests you have the right to object to that.  If your objection is valid (for instance in the case of any direct marketing activity) then we will stop processing your personal data for that purpose,

Data portability: You can request a copy of your data in a digital format which you can then supply to another provider when we ae processing your personal data under the lawful basis of performing a contract with you or because we have your consent,

Automated decisions and profiling: You have the right, in certain circumstances, not to be subject to decisions based on automated processing (including profiling) if it has a significant or legal impact on you.  This doesn’t apply if the processing is necessary to fulfil a contract with you, or if you have given us your consent to do so.  We do not currently use any technology to make automated decisions about you.

COOKIES – HOW DO WE USE COOKIES ON OUR WEBSITE

We utilise cookies on our website.  Some are required for our site to work, these are known as essential cookies, and we also use others for analytics and marketing purposes.

We will ask for your consent to use any cookies which aren’t essential, and we won’t deploy any non-essential cookies without your consent.

These are cookies we use:

WHAT HAPPENS WHEN I FOLLOW LINKS TO OTHER SITES?

If you follow a link from our site to another site then you should read the privacy notice on the other site prior to providing your data to them.

WHERE DO WE PROCESS DATA?

We primarily process data in the UK.

Our web hosting providers process data in the UK.

We use some other software tools and partners to help us deliver our services, some of these services will mean that your personal data are transferred outside of the UK and EU.  We always ensure that appropriate protections are in place to safeguard your rights, as detailed below:

  • Our IT Systems (Microsoft Office 365) – some transfers to the USA using Standard Contractual Clauses,

  • Our CRM system and email distribution provider (Sharpspring) - some transfers to the USA enabled via the UK-US Extension to the EU-US Data Privacy Framework

  • Our partner company in Finland, enabled by Finland holding UK adequacy

  • Our partner company in the USA, enabled by both businesses having agreed to a UK International Data Transfer Agreement

MAKING A COMPLAINT

Please contact us at the above address. You can also contact the Information Commissioner’s Office (ICO) on their helpline 0303 123 1113 or online at www.ico.org.uk. If you should contact the ICO they will normally ask you to contact us first.