Privacy Policy

Published on 22/07/2022

As part of its activity, STEP PHARMA as defined in Article 1 below (hereinafter “STEP PHARMA”), is required to process personal data concerning the user (hereinafter, the “User”) consulting the website available notably at the following URL https://www.step-ph.com/ (hereinafter the “Website”) and/or wishing to obtain services or information offered by STEP PHARMA in particular on such Website (the “Services”).

The present privacy policy (hereinafter, the “Privacy Policy”) is an information note which, in accordance with the amended French Act no. 78-17 of  January 6, 1978 on Information Technology, Data Files and Civil Liberties (hereafter, “Loi Informatique et Libertés”) and the General Data Protection Regulation 2016/679 of April 27, 2016 (hereinafter, “RGPD”) (hereinafter, collectively the “Regulations”), is intended to inform the natural persons concerned about the way in which STEP PHARMA collects and processes, as data controller, such personal data and about the means available to the natural person concerned to control this use.

“Personal Data”: Any data relating to a natural person and likely to contribute to the identification of the latter, directly or indirectly, whether this data is confidential or public.

STEP PHARMA is aware of the importance of respecting privacy and is particularly vigilant about the collection, processing and protection of Personal Data in accordance with the Regulations in order to ensure the best possible level of confidentiality and service.

The use of the Website and the Services as well as the Personal Data communicated within the framework of this use are subject to the provisions of the Privacy Policy. The present Privacy Policy is completed, where applicable, by specific information detailed on the data collection forms.

By using the Website and/or using the Services, the User therefore accepts the Privacy Policy.

1. Who is the data controller?

The person responsible for processing your personal data is:

STEP PHARMA SAS

Simplified joint stock company with capital of 1.148.017,90 Euros

Paris Trade and Companies Register identification number (RCS Paris): 802 795 906

SIRET identification number: 802 795 906 00014

Head office address: 15 rue Louis et Auguste Lumière, Technoparc du Pays-de-Gex, 01630 Saint-Genis-Pouilly, France

Intracommunity VAT number: FR47802795906

You can reach the Data Controller by contacting him via the email address: StepPharmaDPO@ClinicalDPO.com

2. What Personal Data does STEP PHARMA collect?

STEP PHARMA collects and processes the following Personal Data:

• “Contact Us” form: name, email address, eventual Personal Data mentioned by the User in the message request

In any event, the Personal Data collected will however be limited to the data necessary for the purposes set out in the section below.

In addition, when consulting the Website, STEP PHARMA may collect certain Personal Data through cookies placed on your terminal. The collection methods are provided in the dedicated “Cookies” page.

3. When and why does STEP PHARMA collect Personal Data?

The Personal Data collected by STEP PHARMA is necessary for the performance of the Services offered by the latter on the Website and, more precisely, to achieve the following goals and purposes:

• management of STEP PHARMA’s communications.
• management of registrations for events organized by STEP PHARMA;
• processing of your requests via the Website (“Contact Us” form);
• improvement of the content and navigability of the Website (cookies).

Subject to the applicable legislation and in particular the provisions of article L.34-5 of the Postal and Electronic Communications Code, by providing e-mail address and by checking the box “I am neither a customer nor a professional and I wish to receive commercial information from the company STEP PHARMA” the User expressly authorizes STEP PHARMA to use it with other Personal Data useful for sending commercial or marketing messages concerning services offered by STEP PHARMA. If the User is already a STEP PHARMA customer and if these messages concern services similar to those provided to the User by STEP PHARMA, these messages may be sent to the User without his/her prior consent having been obtained.

The User can unsubscribe from communications by contacting STEP PHARMA or by clicking on the link provided for this purpose and referred to at the footer of e-mails sent by STEP PHARMA.

4. On what basis does STEP PHARMA collect Personal Data?

In general, STEP PHARMA uses Personal Data, depending on the processing concerned, on the basis of the following legal bases:

• Processing is necessary to perform the Services offered on the Website;
• Processing is necessary for compliance with a legal or regulatory obligation to which STEP PHARMA is subject;
• The User has given his/her consent to the processing;
• The processing is necessary for the purposes of the legitimate interests pursued by STEP PHARMA when this does not derogate from the User’s own interests, freedoms and fundamental rights.

5. Who has access to the User’s Personal Data?

Personal Data is reserved for the single use of STEP PHARMA and its employees.

The Personal Data collected may however be communicated to third parties bound by contract to STEP PHARMA, for the performance of subcontracted services and / or necessary for the performance of the Services.

Before any transfer of information, STEP PHARMA checks the conformity of the purpose of each request and guarantees the transmission of the elements strictly necessary for the performance of the Services.

To date, the other providers identified are:

• The Website host Thumb Digital Media Design Ltd

As such, it is specified that these third parties will only have limited access to the Data necessary for the performance of their services and will be required to use them in accordance with the provisions of the Regulations.

In any case, STEP PHARMA does not transfer, sell or rent the Personal Data collected to third parties, whether for payment or free of charge.

If STEP PHARMA learns that a third party to which STEP PHARMA has communicated Personal Data for the purposes set out above, uses or discloses Personal Data without complying with this Policy or in violation of applicable legislation, STEP PHARMA will take all reasonable measures to prevent or end such use or disclosure.

Furthermore, in cases where the law requires or authorizes it to do so, in particular due to a Court decision or any other legal request or requirement, STEP PHARMA may be required to disclose this Data to third parties.

STEP PHARMA may also be required to transfer Personal Data to third parties to protect its legal interests (for example, in the event of the sale of a change of control of STEP PHARMA, or the total or partial liquidation of STEP PHARMA).

These transfers may take place via the Internet or by any other method deemed appropriate by STEP PHARMA in accordance with the applicable legislation.

The Website is hosted on servers located in United Kingdom. STEP PHARMA keeps Personal Data on secure servers located in the territory of the European Union.

Personal data may be transferred, for technical reasons, outside the European Union. If this were the case, STEP PHARMA would take care to provide appropriate guarantees such as in particular the use of the standard data protection clauses adopted by the European Commission in order to ensure an adequate level of data protection as well as any additional measures deemed useful (audit providers …).

6. What security measures does STEP PHARMA implement to protect Personal Data?

STEP PHARMA undertakes to implement and enforce the electronic, physical and organizational security measures it deems necessary in order to ensure the confidentiality of the Personal Data collected for the duration of their processing. These provisions aim to offer a maximum level of protection against loss, leakage, alteration, corruption, unauthorized access or transfer or any improper use made of Personal Data under the control of STEP PHARMA.

All Personal Data being confidential, their access is limited to STEP PHARMA employees and service providers who need it in the performance of their mission. All persons having access to Personal Data are bound by an obligation of confidentiality and are exposed to disciplinary measures and / or other sanctions if they do not comply with these obligations.

If the User has reason to believe that the security of his/her Personal Data has been compromised or that they have been misused, the User is invited to contact STEP PHARMA at the email address indicated in Article 1 above.

7. What is the retention period of the Personal Data?

STEP PHARMA retains Personal Data for no longer than necessary for the performance of the Services and, more generally, for the afore-mentioned purposes for which it was collected, subject to STEP PHARMA’s legal obligations to retain specific data or to the legal boundaries for archiving and anonymizing data.

The necessary retention period of Personal Data is defined according to the quantity, nature and sensitivity of the Data, the potential risk of damage in the event of fraudulent use or disclosure, the purpose assigned to processing the Personal Data, and whether it is possible to achieve this purpose by other means, as well as the applicable legal requirements.

You will find below an informative list of the time limits for storing Personal Data:

• With regard to the data collected to respond to one or more of the User’s requests within the framework of commercial relationship, his/her Personal Data is kept for the duration of this relationship and then further legal deadlines requiring STEP PHARMA to keep the User’s Personal Data (common law prescription of 5 years applicable in civil and commercial matters…).
• Regarding the data collected to inform the User of STEP PHARMA’s commercial offers or events: User’s Personal Data is kept for a period of 3 years from the last meeting with the latter.
• Regarding the Personal Data collected in the context of recruitment requests, the data is kept for a maximum of 2 years from the last contact with the candidate.
• Regarding the technical data of connection, navigation, cookies: this data is kept for a maximum period of 6 months.

After these deadlines, STEP PHARMA may archive the Personal Data necessary for the exercise of a right and for proof of this right, within the limit of the applicable limitation / foreclosure period after which the Personal Data concerned is deleted.

For more information on how long your Personal Data is kept for a specific purpose, please contact STEP PHARMA at the following address: StepPharmaDPO@ClinicalDPO.com

8. What are the User’s rights?

According to Articles 15 to 22 of the GDPR, any data subject providing evidence of his/her identity has a right of access, rectification, opposition, portability of his/her Personal Data and to obtain restriction of processing as well as to decide of the fate of such data after death. These rights can be exercised by contacting STEP PHARMA by mail or email at the addresses mentioned in Article 1 above.

Anyone whose Personal Data has been collected by STEP PHARMA has the possibility to contact the French Data Protection Authority (“CNIL”) (whose contact details can be found at https://www.cnil.fr/fr/vous-souhaitez-contacter-la-cnil) if STEP PHARMA has not answered the request within one month. Once the person has been informed that STEP PHARMA received his/her request, this period may be extended to two months, depending on the complexity and the number of requests.

9. What cookies does STEP PHARMA use?

During visits to the Website, STEP PHARMA may collect, in accordance with applicable legislation, information relating to the terminals on which the Website is used or to the networks from which the Website is accessed, such as in particular: IP addresses, connection data, types and versions of internet browsers used, types and versions of your browser plugins, operating systems and platforms, data concerning the navigation path on the Website, in particular the path on the various pages of the Website, the content consulted, the search terms used, the duration of consultation of certain pages, interactions with the page as well as any telephone number used to contact STEP PHARMA.

Among the technologies used to collect this data, STEP PHARMA uses cookies in particular.

Cookies correspond to small files of letters and numbers downloaded to the User’s terminal when he accesses the Website.

These cookies are functional cookies and cookies necessary for the operation of the Website

These cookies are exclusively placed by STEP PHARMA and are necessary for the proper functioning of the Website and its functionalities in order to provide the User with comfortable browsing. They can allow the Website display to be adapted to the preferences of the User’s terminal and the viewing software installed on this terminal.

Deactivation of such cookies by the User could degrade or even prevent the use of certain features of the Website.

10. Privacy policy for minors

The services offered on the Website are not intended for minors within the meaning of French regulations. Anyone under the age of 18 should not use the Services.

Under these conditions, STEP PHARMA does not voluntarily collect personal data from children under the age of 18. If STEP PHARMA was nevertheless brought to the attention of STEP PHARMA of the collection of such data, STEP PHARMA will take all necessary measures to delete this data.

11. Links to third party Websites

The Website may contain links to third party websites, which are governed by their own confidentiality and cookie management policies, conditions of use and security measures, which may differ from those of STEP PHARMA

STEP PHARMA cannot be held responsible for the content and practices of these websites. STEP PHARMA recommends to the User to consult their privacy policy before transmitting any information or Personal Data.

12. How to contact STEP PHARMA in case of questions or problems relating to Personal Data?

Do not hesitate to contact STEP PHARMA for any questions concerning the collection, processing or any need for information concerning your Personal Data notably by sending STEP PHARMA a mail or an email to the addresses mentioned in Article 1 above.

13. Modification of the terms of the Privacy Policy

This Privacy Policy may change, in particular due to legislative and regulatory changes. If necessary, the modifications made will take effect on the date indicated at the top of the present Privacy Policy. By continuing to use the Website and the Services after this date, the User accepts the changes made.

STEP PHARMA encourages the User to consult the Privacy Policy each time he/she uses the Website, in order to stay informed of the information practices in place and the means that the User can use to protect privacy.