The Company Relife Srl (“Company”, or “we”) wishes to inform you that the processing of your personal data, performed by way of the website (“Website”) or collected by way of contact forms (“Forms” or “Form”) takes place in compliance with the applicable data protection law (Regulation (EU) 2016/679 – hereinafter referred to as “GDPR”) and Terms & Conditions of the Website.
Data Controller is Relife Srl with registered offices in Via dei Sette Santi 1, Florence, Italy (“Controller”). The Data Protection Officer (“DPO”) can be contacted at: dpo@menarini.com
We process the following ordinary which you provide when you interact with the Website and use the related services and functions. These data include, in particular name* and surname*, contact details (including email address*, phone number and address) and content of your specific requests or reports and the additional data which the Controller may acquire, also from third parties, in the course of business. In the event that you give your consent (optional) for profiling purposes, the following data will also be processed: user; session; date and time; page visited; time spent on the page; video run; materials downloaded and articles viewed, if any ( collectively “Data”).
In order to enable us to fulfil the requests you send by means of the contact form/manage your registration with the restricted access area/manage it is necessary to provide the data marked with an asterisk (*). Without those mandatory we cannot proceed any further. Conversely, the information requested in fields not marked with an asterisk are optional: failure to provide them shall have no consequence.
The Data is processed for the following purposes: to manage your requests for information/registration with restricted access areas submitted through the Website and Form and grant you access to our materials about our products and services; the legal basis of the personal data processing for these purposes is the performance of a contract with you (i.e., to sign up for the Relife Academy educational program)(art. 6.1.(b) of the GDPR). Without such processing you will not be able to access the restricted access area and/or benefit from our educational program.
Moreover, with your consent - which constitutes the legal basis of the processing pursuant to Article 6.1.a. and 9.2.a. of the GDPR - the Data you submit via the Forms (including any sensitive data you would like to share) will be processed to follow up on the requests. These may include: requests to be visited/contacted, requests to receive general information about our products and services, medical information enquiries. In such cases, the data controller is the Relife company based in the country where you practise or, if there is no Relife company in your country, Relife srl(the contact details of such Relife companies are accessible by visiting the Website www.relife-
Furthermore, but only with your additional, optional consent - which constitutes the legal basis of the processing pursuant to Article 6.1.a. of the GDPR - Company may process your Data to:
(i) send you promotional materials on Company’s products and services (“direct marketing”) via email or via other digital means. Be aware that such communications may contain "Pixel Tags," through which the Company detects certain information, for example, if and when you opened and/or deleted the email, which links you clicked on, the email client you use, whether the email was opened using more than one IP address, as well as some anonymous and aggregate information about users' geographic location, etc.
(ii) personalise the contents addressed to you based on the professional interests and preferences you have shown by using our Website or, where applicable, on occasion of digital communications addressed to You (“profiling”). To do so, the Company will track the actions you do on the restricted area of the Website while you are logged in with your Menarini Digital Identity (“MDI”) credentials and/or with your other credentials, and/or in the context of the digital communications addressed to you (e.g. login, duration of the Website uses, preferred topics, preference to attend a certain training session, links/contents you clicked on etc.). These tracking activities will enable us to infer certain information about you and your usage behaviours and link them to your profile (e.g. your level of enjoyment of the Website, your professional preferences and interests, etc.); we will use such information to provide and suggest contents that are in line with your professional interests and preferences.
If you deny the optional consents described under points (i) and (ii) above, you may still access the restricted access area and use the services available therein.
By ticking the appropriate boxes you provide your consent/s and agree to the processing of your Data for these purposes.
Your Data may in any case be processed, even without your consent, for the purpose of complying with laws, regulations, EU Law (art 6.1.(c) of the GDPR, to perform statistics on the Website’s usage and ensure its proper functioning (art. 6.1.(f) of the GDPR), to enforce the Code of Conduct of the Menarini Group and to establish or defend the legal claims in the interest of the Company.
The Data are entered into the Company computer system in full compliance with data protection law, including security and confidentiality profiles and based on principles of correct practice, lawfulness and transparency in processing.
Data shall be stored for as long as strictly necessary for the attainment of the purposes for which they were collected. In any event the criterion used to determine that period is based on compliance with the time limits set by law and with the principles of data minimisation, storage limitation and rational management of archives.
All your Data will be processed on paper or by means of automated instruments, which in any case ensure an appropriate level of security and confidentiality.
If you only visit the Website (i.e., without sending communications or using any of the available services/functions), the processing of your data is limited to browsing data i.e., data whose transmission to the Website is necessary for the functioning of the computers which operate the Website and of the Internet communication protocols. This category includes, for example, IP addresses or computer domains used to visit the Website and other parameters pertaining to the operating system used to connect to the Website. The Company collects these and other data (such as, for example, number of visits and time spent on the Website) merely for statistical purposes and in anonymous form in order to monitor the functioning of the Website and improve its performance. Such data is not collected to be associated with other information regarding, or for the identification of, users; however, such information, by its very nature, may enable the Company to identify users through processing and association with data held by third parties. Browsing data is normally deleted following processing in anonymous form but can be stored and used by the Company to detect and identify perpetrators of any computer offences committed to the detriment of the Website or using the Website. Without prejudice to this possibility and to the provisions of the Cookie Policy the browsing data described above are stored only temporarily, in compliance with law.
This Information Notice applies only to the Website and the Forms as defined above. Even though the Website may contain links to other websites (known as third party websites), please be informed that the Company does not perform any access or control over cookies, web beacons or other user-tracking technologies that may be active on such third party websites, on the contents and materials published thereon, or on their methods of processing of your personal data; for this reason, the Company expressly declines any liability for such matters. You should therefore verify the privacy policies of such third party websites and collect information about their terms and conditions and about how they process your personal data.
The Data is processed electronically and manually according to procedures and logics relating to the above-mentioned purposes and are accessible by the Controller’s staff authorised to process personal Data and their supervisors, and in particular to staff belonging to the following categories: technical, IT and administrative staff, sales reps, product managers, internal audit and compliance staff, as well as other individuals who need to process the Data to perform their job duties. The Data may be communicated, also in countries outside the European Union (“Third Countries”) to: (i) institutions, authorities, public bodies for their institutional purposes; (ii) professionals, independent consultants –individually or in partnerships- and other third parties and providers which supply to the Controller commercial, professional or technical services required to operate the Website (e.g., provision of IT and Cloud Computing services), in order to pursue the purposes specified above and to support the Company with the provision of the services you requested; (iii) third parties in the event of mergers, acquisitions, transfers of business -or branches thereof, audits or other extraordinary operations; (iv) company supervisory bodies, based at the Controller’s address, in the pursuit of their activities (oversight over the enforcement of legal obligations, ethical standards, the Menarini Group’s Code of Conduct, etc.).
The mentioned recipients shall only receive the Data necessary for their respective functions and shall duly undertake to process them only for the purposes indicated above and in compliance with data protection laws. The Data can furthermore be communicated to the other legitimate recipients identified from time to time by the applicable laws. With the exception of the foregoing, the Data shall not be shared with third parties, whether legal or natural persons, who do not perform any function of a commercial, professional or technical nature for the Controller and shall not be disseminated. The individuals who receive the Data shall process them, as the case may be, in the capacity as Controller, Processor or person authorised to process personal data, for the purposes indicated above and in compliance with data protection law.
Regarding any transfer of Data outside the EU, including in countries whose laws do not guarantee the same level of protection to personal data privacy as that afforded by EU Law, the Controller informs that the transfer shall in any event take place in accordance with the methods permitted by the GDPR, such as, for example, on the basis of the user’s consent, on the basis of the Standard Contractual Clauses approved by the European Commission, by selecting parties enrolled in international programmes for free movement of data or operating in countries considered safe by the European Commission.
By contacting the Controller at the addresses indicated above you can, at any time, exercise the rights pursuant to Articles 15-22 of the GDPR such as, for example, obtaining an updated list of the individuals who can access your Data, obtain confirmation of the existence or otherwise of Data which relates to you, verify their content, origin, correctness, location (also with reference to any Third Countries ), request a copy, request their rectification and, in the cases provided by the GDPR, request the restriction of their processing, their erasure, oppose to direct contact activities (including limited to some mediums of communication), revoke your consents at any time - however that shall not impair the lawfulness of the processing carried out before consent withdrawal, etc..
Likewise, you can always report observations on specific uses of the data regarding particular personal situations deemed incorrect or unjustified by the existing relationship to the DPO or submit complaints to the Data Protection Authority.
rev. 14 May 2024
Having read the privacy policy, I consent to the processing of my data by Relife Srl or the Relife company based in the country where I practice.
REL-MLTA-27-2024