Privacy Policy

This is the Privacy Policy of CS Pharmaceuticals Limited (‘CSP’).

CS Pharmaceuticals Limited (‘CSP’) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tells you about your privacy rights and how the law protects you.

1. Purpose of this privacy policy

This privacy policy aims to give you information on how CSP collects and processes your personal data though your interactions with us.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them.

2. Controller

CSP is the controller and responsible for your personal data (also referred to as ‘we’, ‘us’ or ‘our’ in this privacy policy).

3. If you have any questions about this, please contact us in writing:

CS Pharmaceuticals Limited
Level 30, The Leadenhall Building,
122 Leadenhall Street,
London, EC3V 4AB

info@cspharmaceuticals.com

Alternatively, you have the right to make a complaint to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk).

4. Changes to the privacy policy

This version was last updated on 1 October 2021.

5. Please keep us updated about your details

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your time working with us.

6. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer various kinds of personal data about you, which we have grouped together follows.

- Identity Data includes first name, last name, or similar identifier, and title
- Contact Data includes billing address, delivery address where applicable, email address and telephone numbers
- Financial Data includes bank account details
- Transaction Data includes details about payments to and from you
- Technical Data (collected automatically) includes internet protocol (IP) address, 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 website
- Profile Data includes services we have provided for you, your preferences and feedback responses
- Marketing and Communications Data includes your preferences in receiving information about our services and your communication preferences

Special Categories of personal data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any Special Categories of personal data about you.

7. 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 services we have agreed with you. These circumstances may necessitate us cancelling the contract, services provision agreement or statement of work that we have with you.

8. How we collect your personal data

We use different methods to collect data from and about you. These include the following methods.

Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by email, phone, post or otherwise.
Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using server logs and other similar technologies
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, such as website analytics and search engines
Contact, Financial and Transaction Data from providers of technical, payment and delivery services
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

9. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances

Where we need to deliver on the terms of the contract or service agreement that we have entered into or are about to enter into with you
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
Where we need to comply with a legal or regulatory obligation

Generally, we do not rely on consent as a legal basis for processing your personal data.

You have the right to ask us to delete your personal data at any time by contacting us: info@cspharmaceuticals.com

10. Purposes for which we will use your personal data

We have set out below a description of all the ways we may use your personal data, and which of the legal frameworks we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose	Type of data	Lawful basis for processing
To register you as a new client or supplier	Identity Contact	Performance of a contract with you
To process and deliver our service to you including: Manage payments, fees and charges Collect and recover money owed to us Identity Contact Financial Transaction Marketing and communications		Performance of a contract with you. Necessary for our legitimate interests.
To manage our relationship with you including: Notifying you about changes to our terms or privacy policy Asking you to leave a review	Identity Contact Profile Marketing communications	Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical information	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To use data analytics to improve our website	Technical	Necessary for our legitimate interests (to keep our website updated)
To make suggestions and recommendations to you about services that may be of interest to you	Identity Contact Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

11. Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at any time: info@cspharmaceuticals.com

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service agreement or contract that we have entered into with you

12. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required and permitted by law.

13. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

14. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, altered, disclosed, used or accessed in an unauthorised way. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

15. Data retention

How long will you use my personal data for?

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, accounting, insurance valuation or reporting 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 unauthorised 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, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available upon request from us.

16. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

If you wish to exercise any of your rights, please contact us: info@cspharmaceuticals.com

- No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

17. What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other 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.

18. Time limit to respond

We try to respond to all legitimate requests within 28 days. If your request is particularly complex or you have made a number of requests it may take us longer than 28 days to respond. In this case, we will notify you and keep you updated.

19. Lawful basis

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

20. Your legal rights

You have the following legal rights.

- Request access to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request
- Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  1. If you want us to establish the data’s accuracy
  2. Where our use of the data is unlawful, but you do not want us to erase it
  3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
  4. You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.