In this privacy statement, we, Truvion Holding B.V. (“Truvion”) or “we”/“us”), explain how we deal with the personal data of our customers, potential customers and other persons with whom Truvion contracts with or has contact with, directly or indirectly (customers, suppliers, and where appropriate, their suppliers). Truvion Healthcare Logistics B.V., Truvion Healthcare B.V., Santesa B.V. and Truvion Healthcare N.V. are subsidiaries of Truvion. As a logistics service provider in the pharmaceutical industry, Truvion Healthcare Logistics B.V. provides logistics services for small to medium-sized pharmaceutical and medical companies in the Netherlands and abroad, and processes personal data in that context. Truvion Healthcare B.V., Santesa B.V. and Truvion Healthcare N.V. bring products onto the market and in doing so, make use of websites and online shops. Personal data is data that can reasonably be traced to an individual.
How we obtain personal data
We collect personal data by various means, one being that you have provided it to us. For example:
- when you contact us through one of our company websites;
- when you come into contact with us through one of our consumer-oriented websites, such as by email, telephone, WhatsApp or our social media channels;
- when you register through our website and/or make purchases;
- when you request product-related and other information;
- when you enter into a contract with us; or
- because you use our website(s) and in doing so, enable us to record data about your interests and preferences.
We also process personal data that we obtain from our own observations or derive from your use of certain services or facilities, for example:
- your communication preferences;
- data relating to the means by which you communicate with us, such as an IP address or other number;
- data that we link to certain patterns, such as a status in the profile that we compile about you based on your consumption behaviour (such as the frequency with which you visit our website, make a purchase or purchase a service).
We may process your data that relates to you as a consumer, such as when you contact us about a specific product, or data that relates to you as an employee or representative of a company or organisation, or if you’re a business partner or represent one.
If you do not supply data that you are required to enter (as will be shown on a case-by-case basis), the consequence may be that we are unable to fulfil certain contractual obligations. Some products and/or services are offered by our partners and sometimes reference is made to websites of such partners or other third parties. This is clearly indicated. The privacy statement of these parties show how these parties handle your personal data.
We may use personal data on the basis of six different principles, which are specified in the law:
- your permission;
- the need to use personal data for the implementation of an agreement/agreements to which you are party, or to take the measures desired by you before the agreement is entered into;
- to represent our legitimate interests or those of the organisation with which we can and will share your details;
- to comply with a legal obligation;
- to represent your vital interests as an involved party; and
- the need to process personal data for the performance of a task that is in the public interest.
The legitimate interests of Truvion or a third party are: marketing, advertising, communication, research into and analysis of own products or services, establishing which products and services are most likely to be of interest to people, IT management and security, business management, legal affairs, internal management, and sharing information with parties affiliated with us.
Purposes of and principles for the processing of personal data
We process your personal data for certain purposes described below:
- responding to requests (e.g. replying to questions or requests for information, creating an account or sending brochures);
- in the context of a purchase or service agreement that you (or your company) enter into with Truvion;
- offering, organising and completing competitions and promotions, for legitimate interests or because you are entering into an agreement for that purpose;
- offering customer service, including service relating to the purchase of services and/or products and handling complaints and requests, due to an agreement to which you are a party, legal obligations, and/or our legitimate interests;
- sending surveys, newsletters and marketing and service messages by email, telephone, mail, social media and/or other channels. With direct marketing, you always have the option of unsubscribing by objecting or withdrawing your permission, if you’ve given it;
- conducting market research to improve our business operations, brands, services and products, and to chart the wishes of customers on behalf of legitimate interests;
- improving our communication by tailoring it to your personal preferences, on behalf of our legitimate interests;
- implementing or coordinating any recall campaigns due to legitimate interests or legal obligations;
- analysing your surfing behaviour using cookies or similar techniques, with your permission where required and otherwise on behalf of our legitimate interests.
Among other things, Truvion operates online shops aimed at consumers and collaborates in doing so with Truvion Healthcare Logistics B.V. In this context, in addition to the foregoing, personal data are also processed for the following purposes in order to prepare, implement or assess an agreement to which you are a party:
- handling and administering payment transactions;
- handling and administering orders;
- delivering orders;
- posting and responding to reviews.
Sharing with third parties
Your personal data is shared with:
- delivery services and parties that send messages as instructed by us;
- parties that assist Truvion in the provision of its services and that are not processors (for example, accountants and legal and other advisors), on behalf of our legitimate interests;
- existing or potential purchasers or investors, for legitimate business economics purposes (such as the sale or possible sale of business activities or shares or a reorganisation);
- authorities that take enforcement action, including investigative authorities or other third parties, if we are legally obliged to do so.
We will transfer your data to the parties specified above only to the extent permitted by the applicable laws and regulations.
Some third parties engaged by Truvion qualify as ‘processors’ (such as hosting service providers, certain software suppliers, mobility service providers or parties that organise or carry out campaigns or studies). Agreements are made with such parties in accordance with the applicable legal requirements.
Profiling and cookies
Transfer outside of the EEA
If we transfer your data to a country outside of the EEA, we will inform you about this and will take appropriate security measures to lawfully transfer the personal data to such countries. Please contact us if you wish to view a copy of the relevant guarantees.
Your rights, including the right to object
You have the right to know which personal data we hold about you and for what purposes, and the right to view this data and amend it where necessary. If you have given permission, you can revoke it at any time, and the relevant processing will cease as of that moment. In addition, in certain cases you have the right to object to processing related to direct marketing and processing based on the ‘legitimate interest’ principle, and to request us to limit the use of your personal data or to delete it or transfer it (data portability). You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). You can only exercise these rights to the extent permitted by the applicable legislation.
The contact details for Truvion Holding B.V. can be found at the bottom of this privacy statement.
With regard to certain requests, we reserve the right to reject your request where legally permissible.
In principle, we do not store your personal data for any longer than necessary for the purposes for which it was obtained and to comply with our legal obligations. This generally means that your personal data will be stored for as long as one of the following situations applies:
- your personal data is necessary for providing you with products or services;
- your personal data is necessary for protecting and defending our rights and property (normally for the duration of the applicable legal limitation period); or
- we are required by law and regulations to store your personal data, for example due to tax legislation.
Changes to this privacy statement
We reserve the right to unilaterally change or supplement this privacy statement. We announce changes on our website if we are legally required to do so.
If you have any questions or comments about this privacy statement and/or the processing of personal data, you can contact us via:
Truvion Holding B.V.
1382 JS Weesp
+31(0)294 461 122
+31(0)294 461 170
This privacy statement was last updated on 26 June 2018.