Privacy Policy

1. Data Controller

Owner: Adalvo Limited (“Adalvo”)
Address: Malta Life Sciences Park, Building 1, Level 4, Sir Temi Zammit Buildings, San Gwann Industrial Estate, San Gwann SGN 3000, Malta
VAT Number: MT25620308
Telephone number: +356 22485944
E-mail: dataprotection@adalvo.com

2. Purpose of Personal Data Processing and Legal Basis

Personal Data (“Data”) will be processed by Adalvo depending on the purpose for which it has been collected (“Purposes”):

1. Based on the concerned user’s consent. To respond to consultations or requests, as well as to send Adalvo’s commercial communications, it is necessary that the concerned user gives their consent to the processing of Data. User consent may be withdrawn at any time, although this will not affect any processing that has been carried out by Adalvo previous to such withdrawal. Concerned users may unsubscribe from these communications at the following e-mail address: dataprotection@adalvo.com
   Article 6.1.(a) of the Regulation (EU) 2016/679 – GDPR.
2. Based on the performance of a Contract, compliance of legal obligations or cooperation with competent Authorities.
   Article 6.1.(b) and (c) of the Regulation (EU) 2016/679 – GDPR. 
3. Based on Adalvo’s legitimate interests. Adalvo may process Data to satisfy certain legitimate interests, such as but not limited to:  (i) infraction prevention, (ii) detection and investigations including fraud and money laundering or financing of terrorist acts, (iii) analysis and administration of commercial risks, (iv) in relation with any claim, action or procedure (including, but not limited to, drafting and reviewing documents, drafting necessary documents for the conclusion of a transaction, obtaining legal advice and facilitating settlements) and/or protection or exercise of contractual and legal rights and obligations, and (iv) cooperation with public Authorities. Adalvo’s legitimate interests do not prevail over a subject’s rights and fundamental freedoms.
   Article 6.1.(f) of the Regulation (EU) 2016/679 – GDPR.

3. What categories of Data does Adalvo process?

Adalvo processes the following Data categories:

1. Data obtained directly from an interested or third party.
2. Data obtained from an interested party through the “Contact Us” form on Adalvo’s web site https://www.adalvo.com/ (“Web Site”).
   • First and last name
   • E-mail address
3. Data obtained as a result of an interested party’s visit to the Web Site (see our Cookie policy https://www.adalvo.com/cookie-policy). 
4. Data obtained from an interested party reporting a possible side effect related to an Adalvo product. 
   • First and last name
   • Contact information (postal address, email, or telephone number)
   • Qualification (if the subject is a healthcare professional)
   • Information regarding the person who experienced the possible side effect (initials, date of birth, age/group of age, gender, or gestational period)
   • Description of the possible side effect (signs and symptoms experienced, date the possible side effect started and the result of the possible side effect)
   • Name of the Adalvo product involved.
5. Data obtained automatically or from other sources (including but not limited to following mergers or due to disclosure from the report of possible side effects related to an Adalvo product – where in such cases, Adalvo will consider that the interested party authorized the disclosure of Data themselves). 

Each interested party guarantees that the Data provided is true, accurate, complete, and up to date, being responsible for any damage or prejudice, direct or indirect, that could be caused as a result of the breach of such obligation. If the interested party provides Data of third parties, he/she declares to have the consent of the same and undertakes to transfer the information contained in this Section to such third party, exempting Adalvo from any liability in this regard. However, Adalvo may carry out verifications to confirm this fact, adopting the corresponding due diligence measures, in accordance with data protection regulations.

4. How long does Adalvo keep your data?

Adalvo will store Data for the period of time (i) necessary for Adalvo to comply with the specific legal obligations in its business area, (ii) in accordance with the applicable statute of limitation or (iii) for the observance of the archiving obligations imposed by the applicable legislation.

Regarding the sending of commercial communications, Data may be kept indefinitely until the interested party opposes such processing of Data by Adalvo.

5. Who are the recipients of the Data?

Adalvo will disclose the Data to the following recipients:

1. Adalvo’s affiliated companies.
2. Adalvo’s collaborators or partners (including, but not limited to IT partners, auditors or legal consultants, and public Authorities or bodies).

Any transfer of Data outside the European Economic Area will be conducted with the observance of the legal provisions, by applying appropriate safeguards, such as standard contractual clauses approved by the European Commission for international data transfers, and notifying any interested party, as the case may be.

6. Privacy Statement for Children

Adalvo’s Web Site is directed to an adult audience. Adalvo does not purposely process any Data from any person under the age of 16. Data of persons under the age of 16 will be processed only with prior written consent of the parent or holder of parental responsibility. Such legal representative has the right, upon request, to view the information provided by the child and/or to require that it be deleted.

7. Security of Data

Adalvo processes Data in a manner that ensures appropriate security of such Data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.

8. User Rights

Data Protection Rights may be exercised by sending (i) a communication in writing to Adalvo, located at Malta Life Sciences Park, Building 1, Level 4, Sir Temi Zammit Buildings, San Gwann Industrial Estate, San Gwann SGN 3000, Malta, (ii) through the e-mail address dataprotection@adalvo.com, or (iii) at http://www.adalvo.com/contact/. 

Any interested party shall have the following rights:

• Right of access, meaning the right to obtain a confirmation from Adalvo’s part as to whether or not Data is being processed, as well as access to such Data and information on the processing;
• Right to rectification, meaning the right to have, without undue delay, the rectification of inaccurate Data and/or the completion of incomplete Data;
• Right to erasure/right to be forgotten, meaning the right to erase Data without undue delay if such Data is no longer necessary in relation to the Purposes and there is no other legal ground for processing, if Data were unlawfully collected or must be erased for compliance with a legal obligation;
• Right to restriction of processing applicable if (i) the accuracy of the Data is contested by an interested party, (ii) processing is unlawful and an interested party opposes the erasure of the Data, requesting in exchange the restriction of its use, (iii) Adalvo no longer needs the Data, but an interested party requires it for the establishment, exercise or defense of legal claims, (iv) an interested party objected to the processing pending the verification whether Adalvo’s legitimate grounds override theirs;
• Right to object to the processing, except for the cases where Adalvo proves that Adalvo has legitimate reasons for the processing of Data, reasons that override an interested party’s interests, rights, and freedoms or for the ascertaining, exercise, or defense of a right in front of a court of law;
• Right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
• Right to data portability, meaning the right to receive Data provided to Adalvo for the Purposes, in a structured, commonly used, and machine-readable format, as well as the right to transmit Data to another controller; and
• Right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly affects an interested party, except for the case where such processing is necessary for the performance of a contract or authorized by law.

If you consider that Adalvo has violated the rights that are recognized, you may lodge a complaint with the Information and Data Protection Commissioner, by means of the following link.

Adalvo reserves the right to update, modify or delete information contained in this Web Site at any time and may limit or deny access to such information.

From Adalvo we are committed to regulatory compliance and respect for the rights of the people concerned, as well as respect for their privacy, so if you have any questions regarding how Adalvo process’ your Data, please do not hesitate to contact us through the indicated channels.

Last updated: September 2022