LZVO WEBSITE PRIVACY POLICY

Like most website operators, Latvian Medicines Verification Organisation (LZVO) collects data about visitors to our website at www.lzvo.lv. This helps us understand how useful the website is and how to improve it.

LZVO data collection practices are governed by the following Privacy Policy, which tells you what data LZVO collect, how we use that data and who has access to that data.

You have many rights that you can use to control your privacy. LZVO respects those rights. We want to help you exercise your rights, so you will find details on how to do so below.

Please take your time to read this policy and contact LZVO if you have any questions or feedback regarding our privacy policy.

Your data controller

LZVO is the controller of your personal data. Contact information of LZVO can be found here: http://www.lzvo.lv/en/contacts/.

Your LZVO data protection officer can be contacted at e-mail info@lzvo.lv.

What data doES LZVO collect and how is it used?

Website browsing statistics

LZVO is constantly improving its website and aims to make using it as easy as possible. For this purpose, LZVO needs to know what information is most relevant to website visitors, how often they connect, what browser and device they use, what content is mostly read, what region visitors come from, and similar demographics and statistics.

LZVO collects this information by using an automated tool called Google Analytics. This allows LZVO to record and analyse how visitors use the website.

You can learn more about how Google Analytics works and the information it allows us to collect and analyse here –

https://support.google.com/analytics/answer/1012034?hl=lten&ref_topic=6157800 .

LZVO uses this data on the basis of our legitimate interest as a non-profit organisation in improving our understanding of visitor needs and preferences in order to constantly enhance our services and improve visitor access to information that LZVO publishes.

You may at any time disable collection of your data by Google Analytics, as described here - https://tools.google.com/dlpage/gaoptout/.

Logs

The server that hosts the LZVO website may also record requests you make to the server, such as the web address you open, the device and browser you use, your IP address, date and time of access. This data is used only for technical purposes – that is, to ensure the proper functioning and security of the website and to investigate possible security incidents.

The basis for collecting and using such data is LZVO’s legitimate interest in ensuring the technical availability and security of the LZVO website.

Information that you or your employer provides to us in the context of using LZVS

LZVO processes personal data that you or your employer provides to us in the context of using the Latvian Medicines Verification System (LZVS). Use of LZVS is mandatory for all companies involved in the distribution of prescription medication under the applicable law (including Delegated Regulation No. 2016/161). Therefore, if you are employed by such a company, then you or your employer may provide your personal data to us to enable efficient use of our website www.lzvo.lv, including client portal, and otherwise as may be needed for purposes of efficient LZVS use.’’

We may obtain your personal data when you or your employer submits an application for the use of LZVS, when you or your employer indicate you as the contact person for purposes of LZVS use, or when your contact details are collected because you have submitted a document to LZVO in relation to LZVS, or when your data is otherwise obtained from you or your employer in connection with LZVS.

The personal data that we process in the context of LZVS may include your name, surname, title, phone number, and e-mail address.

The legal basis for processing the above-mentioned personal data is to ensure compliance with LZVO legal obligations – to ensure that LZVS is only accessed by properly authorised persons and that all alerts posted in LZVS are properly investigated. Also, your personal data may be processed based on LZVS legitimate interest – to ensure efficient functioning of LZVS and communication with your employer, who is a user of LZVS.


Information that is obtained from other persons

We might supplement the information described above with information we obtain from other sources. It may be obtained either from professional organisations that you are a member to, affiliated companies, European Medicines Verification Organisation or public registers. Such supplemental information could include contact information, education and speciality data, data regarding professional qualifications, data regarding representation rights, address.

The processing of such personal data is necessary for the LZVO to perform contractual and statutory obligations, as well as it allows us to prevent fraud and to ensure that LZVO grants access to the LZVS only to those persons who are entitled to access it under the Delegated Regulation No. 2016/161.

The legal basis for use of such personal data by the LZVO is preparation for entering into contract, performing the contract as well as necessity to comply with statutory obligations.

Cookies

What are cookies?

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. A cookie enables the website to remember your actions and preferences ‒ such as login, language, font size and other display preferences ‒ over a period, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

How does LZVO use cookies?

The LZVO website uses cookies to collect your IP address and browsing information, such as the websites you have visited or the time you have spent on each page and allows the Website to remember your system and preferences.

Other cookies allow LZVO to track website traffic and users’ interaction with the website – LZVO uses this data to analyse visitors’ behaviour and to improve visitors’ experience. These cookies are placed and used by the Google Analytics tool.

Cookies are placed on your device as they are required for technical functioning of the website. However, note that if you do not consent to the use of cookies, certain functions of the website may not function properly or may not function at all.

The legal basis for the use of cookies is LZVO’s legitimate interest in ensuring the technical functionality of the website. When cookies are used to remember your choices or for statistical purposes, the legal basis is your consent.

How to control cookies?

You can control and/or delete cookies as you wish – for details, see http://www.youronlinechoices.com/. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. But if you do this you may have to manually adjust some preferences every time you visit a site, while some services and functionalities may not work.

ANNOUNCEMENTS

If you register to LZVO website or otherwise provide LZVO with your business contact details, LZVO may send you updates, announcements or legal alerts which may be of interest to you and which are related to the implementation and operation of the LZVS or the European Medicines Verification System. You can always refuse from receiving notifications of such communication to email.

Profiling

LZVO may use website visitor statistical data to analyse trends and demographics of LZVO visitors. However, LZVO does not assign each visitor an individual profile.

Who may access your data

Statistical data about LZVO visitors may be accessed by our marketing and IT employees and service providers who are responsible for analysing that data and for improving our website.

LZVO partners who provide LZVO with website content management tools or who host the LZVO website may have access to technical log files. These partners may also view your personal data that are posted in client portal of the LZVO website.

We use third party service provider as first responder for alerts in the LZVS. This partner has access to LZVS system user contact details and contacts them in case of alerts posted in LZVS to assist in resolving the relevant issue. This partner acts as data processor on the basis of a data processing agreement concluded with LZVO.

All LZVO service providers, that have access to personal data, have undertaken to observe confidentiality in regard to any personal data.

The Google Analytics tool provided by Google has access to statistical data collected by that tool. Contractual obligations to ensure privacy are applied to this provider, which you may read here:

https://www.google.com/analytics/terms/dpa/dataprocessingamendment_20160909.html.

How long does LZVO store data?

LZVO uses collected statistical data for analysis for up to three years.

Cookies are usually valid for a short term (a day, a week or a month), though in some cases they may remain valid for up to a year.

Data collected in the context of LZVS (section 2.3 of this policy) will be stored for at least the duration of the contract between your employer and LZVS and after this contract is terminated or expired – for no longer than a period of 10 years, which is the statute of limitation for all civil claims.

Your rights and how you may exercise them

By contacting LZVO via e-mail at info@lzvo.lv, you may exercise your right:

to require access to your personal data;

to require rectification of your personal data;

to withdraw consent to processing of your personal data, where applicable.

In some cases, you may have a right to request a restriction on processing your personal data or to object to processing of your personal data. In such cases you may exercise your right to require erasure of your personal data.

You may exercise your rights in line with the requirements of applicable EU and Latvian laws.

If personal data is erased at your request, LZVO will only retain such copies of the information as are necessary to protect our or third-party legitimate interests, comply with governmental orders, resolve disputes, troubleshoot problems, or enforce any agreement you have entered into with LZVO.

You may disable cookies by your browser settings, or by visiting here:

https://tools.google.com/dlpage/gaoptout/

http://www.youronlinechoices.com/

Right to lodge a complaint

If you think your privacy rights have been breached, you may lodge a complaint with an authority of the EU country of your habitual residence. Contact information for these authorities can be accessed at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.