Data Privacy Policy
The Centre of Excellence (the “Tool”) is an online tool that has been developed with the intention to maintain your product and marketing knowledge on a high level. It empowers you to test yourself regularly as the tests are constantly updated to reflect the latest medical and marketing information available.
The tests are divided into different modules, each consisting of a set of randomly chosen questions. To pass a test 80 % of the questions have to be answered correctly. A test can be repeated as often as required. For every test successfully passed a personalized certificate will be stored in the section “My Pages”. These certificates are valid for 12 months. This area is only accessible for registered users.
In order to evaluate the overall acceptance of the tool the usage is tracked on administrator level in a way that the correct or incorrect answers to a question are statistically analysed. This should help to ensure that the level of difficulty of the single questions and modules is balanced. Any kind of personal usage data is exclusively collected on an aggregated, non-personalized level. The performance of a single user is neither tracked nor evaluated.
This privacy policy applies to data processing in connection with your use of the Tool.
1. Who is responsible for data processing and who may I contact?
The Data Controller is Berlin-Chemie AG, Glienicker Weg 125, 12489 Berlin (hereinafter also referred to as "the company", "we" or "us").
You can reach our data protection officer via the following contact details:
Dr. Wernicke, Data Protection Department, e-mail: dpo.germany@berlin-chemie.de
2. What data do we collect, for what purposes do we process your data and what is the legal basis for the processing?
Your personal data that we process can be divided into the following categories:
- information concerning your person (username), country
- information regarding your knowledge with regard to our products (test results, answers given). The evaluation of answers is only tracked on aggregated level. Countries are grouped in a way that at least 10 users are combined in a set. Results of single users are not evaluated.
We process your data for the purposes of establishing and carrying out a certification mechanism in order to ensure a consistent product knowledge among our employees. We process your data on the basis of Art. 88 paragraph 1 of the EU General Data Protection Regulation (“GDPR”) in conjunction with § 26 paragraph 1, 3, 4 of the Federal Data Protection Act ("Bundesdatenschutzgesetz - BDSG"). For group-wide internal administrative purposes, the legal basis is the legitimate interest of the company or companies of the Menarini Group (Art. 6 paragraph 1, letter f) GDPR).
3. Who gets my data? Is data transferred to a third country or to an international organisation?
Recipients of data:
- within our Company, our employees who process employee data as a result of their work have access to your data only to the extent necessary to fulfill the respective purpose,
- external data processing services providers (e. g. external consultants and contractors, security services, travel agencies, training and education providers),
- companies of the Menarini Group.
4. What are the sources of the data?
We collect this data directly from you.
5. How long do we store your data?
We store your personal data for five years.
6. Your rights
You are entitled to request information about your data stored by us at any time (Art. 15 GDPR). Furthermore, you have the right to request the correction of incorrect data (Art. 16 GDPR) or, under the legal requirements, deletion (Art. 17 GDPR), blocking, restriction of processing (18 GDPR) and transfer of your data (Art. 20 GDPR). You also have the right to object to the processing of your data at any time (Art. 21 GDPR). For the right to request information and the right to cancellation, the restrictions according to §§ 34 and 35 BDSG apply.
In addition, you have the right to lodge a complaint with the responsible supervisory authority, the Berliner Beauftragte für Datenschutz und Informationsfreiheit (Art. 77 GDPR in conjunction with § 19 BDSG).
Berlin-Chemie AG
Stand: February 2020