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Privacy policy


1. Data Controller and Data Protection Officer

1.1. In this privacy statement, A.T.C. PHARMA, which registered office is Avenue Hippocrate n ° 15 in 4000 Liège (hereinafter: "ATC PHARMA" or "we"), explains to you how it manages your personal data as "controller". This privacy statement applies to ATC PHARMA's processing of personal data of customers, potential customers (prospects) and individuals who contract with ATC PHARMA in any other way, as a buyer or supplier. ATC PHARMA has an establishment unit and can be contacted by mail at the address mentioned in point 7.4

1.2. All information concerning an identified or identifiable natural person is personal data. This is information that can reasonably be related to an individual.

1.3. The Data Protection Officer can be contacted by email at:

2. The personal data we process

2.1. ATC PHARMA can collect your personal data in several ways. We process personal data that you provide to us when you contact us, enter into a contract, but also when you participate in an action or use our services and you communicate data to us directly or indirectly or you allow us to record data about your interests, your behavior and your preferences (cookies).

2.2. If you submit a request to ATC PHARMA, for example via the website, we will need the following personal information:

a) Personal identification data (surname, first name);

b) Electronic identification data (e-mail address and other contact data);

c) Possibly other information that is relevant to your request, such as: your activity or other complementary options.

2.3. If you execute a contract with ATC PHARMA or you are applying as a volunteer, we will need the following personal information:

a) Personal identification data (name, first name address);

b) Electronic identification and contact data (telephone number and email address);

c) Company number;

d) Financial data;

e) Medical data;

This personal data must be communicated directly to ATC PHARMA. If you do not provide us with "mandatory" information (which differs depending on the type of contract), we may not be able to provide the requested service and execute the contract.

2.4. If you make use of the services offered by ATC PHARMA or execute a contract with us, we process the data whose main purpose is to test healthy volunteers and / or small groups of patients to assess the risk of tolerance, metabolism and efficacy of new drugs or active molecules (dietary supplements, ...) in Humans (men and women).

3. Foundations and legitimate interests

We treat personal data on the basis of the following legal grounds:

a) Consent of the person concerned;

b) Execution of a contract with you or pre-contractual measures;

c) Legal obligation;

d) Legitimate Interest of ATC PHARMA;

We treat personal data in a legitimate interest when we use your data to provide services and related content, products and services. Our legitimate interests include, for example: communication, IT management and security, research and analysis of our own products or services, business management, legal affairs, internal management and sharing with our affiliates.

4. The purposes for which we process personal data

4.1. ATC PHARMA processes personal data for the purposes (goals, objectives) mentioned below:

  • Under a service agreement with ATC PHARMA;
  • Maintain customer relationships (including maintaining a direct relationship between ATC PHARMA related financial services, including for the performance of a contract and the pursuit of legitimate interests);
  • Recruit volunteers who meet inclusion criteria for clinical trials;
  • Process and evaluate applications for authorizations, certificates, approvals or other types of authorization;
  • Register notifications of manufacture, distribution or export of medical devices;
  • Record, evaluate and analyze reports of adverse drug reactions and adverse events or incidents with medical devices;
  • Perform inspections and controls;
  • Provide scientific advice and information in the area of ​​competence of ATC PHARMA;
  • Selection procedures for recruiting new staff;
  • Data management for external experts to whom ATC PHARMA can call;
  • Managing information about suppliers that provide services to ATC PHARMA.

5. Third parties involved in the treatment

5.1. In some cases, ATC PHARMA shares personal data with third parties, who are independent "controllers". We explain below when and why. ATC PHARMA can share data with:

(a) ATC PHARMA's service partners, for the performance of a contract or for the pursuit of legitimate interests;

b) third parties to whom we are legally obliged or authorized to provide data;

c) third parties, if we suspect a violation of the rights of third parties, criminal offenses or abuses, if they have a legitimate interest or if they are public authorities. It may also be authorities such as the police, the public prosecutor;

d) parties who assist ATC PHARMA in its services and are not sub-contractors of personal data for the pursuit of its legitimate interests;

e) buyers or (potential) investors for legitimate economic and business purposes (such as the sale of business or stock or reorganization);

(g) parties assisting ATC PHARMA in the development of (direct) marketing activities in pursuit of its legitimate interests

5.2. The communication of personal data to the third parties referred to above will take place only if it is authorized on the basis of the applicable laws and regulations.

5.3. ATC PHARMA also uses third-party services that act as "subcontractors" (for example, hosting service providers, certain software providers, mobility service providers or parties that organize or execute surveys for us). With these service providers, ATC PHARMA is obliged to conclude a subcontract which stipulates that they only process personal data in accordance with the instructions and under our control. The list of these subcontractors is available on request by e-mail to the address mentioned in point 7.4.

5.4. Currently, we do not store personal data outside the European Union. If personal data were to be deliberately disclosed outside the European Union, we will take additional safeguards, such as the conclusion of a model EU contract.

5.5. Our websites may contain references and / or hyperlinks to one or more websites of third parties. ATC PHARMA is not responsible for how these third parties process personal data. We recommend that you read the privacy statement of these websites to know and control how they treat your personal data.

6. Marketing, profiling and cookies

6.1. We and third parties automatically collect certain information about the history of your business from our website and third party applications using automated means, such as cookies, in accordance with the preferences you have provided. Through certain cookies and similar technologies, unique cookie IDs or other identifiers are assigned or collected. In this way, data can be collected while you are using the website or applications or when they are running in the background on your machine. We can combine them with other information about you or your machine, such as an IP address. If we need permission for this, we will ask you to do so before proceeding with this treatment.

6.2. We invite you to read our cookie statement for more information about cookies and similar technologies used and how to set your preferences.

7. Your rights, including your right to object

7.1. You have the right to know what personal data we have stored about you and to whom we have disclosed your personal data.

7.2. In addition, you have the right to ask us, in compliance with applicable law, to correct, update, delete your personal data, limit the processing of your personal data or to give your personal data in a structured format, commonly used and machine readable for transmission to another company.

7.3. We are required to bring to your attention your absolute right to oppose direct marketing and your rights to:

- oppose any treatment, including profiling, for the pursuit of the legitimate interests of ATC PHARMA or third party and

- submit a complaint to a data protection authority. In Belgium, it is the Commission for the protection of privacy designated as the Data Protection Authority.

7.4. The rights of access, rectification, limitation of treatment, erasure, or portability of your data, as well as a withdrawal of agreement, can be exercised free of charge by e-mail, form, telephone or mail to following addresses or numbers;

Form via the website
Phone +32 (0)4 366 83 15
Courrier ATC  s.a. /Clinical Pharmacology Unit
CHU Sart-Tilman, Bâtiment B35, Tour 2,
Avenue de l'Hôpital, 1

4000 Liège

8. Security

8.1. We have taken appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing.

8.2. If you have the impression that your data is not properly secured or if you have evidence of improper or irregular use of your personal data, please contact our customer service at the email address mentioned in article 7.4

9. Data retention period

We only store personal data for as long as is necessary for the purposes for which it was obtained, unless we are legally obliged to keep personal data for longer or if this appears necessary for the management of a potential dispute.

10. Modification

10.1. We reserve the right to unilaterally modify or supplement this privacy statement. We will inform you as far as possible of any changes. We advise you to periodically review our privacy statement.

10.2. This privacy statement was last updated on May 25, 2018.

11. Contact / questions

For questions or comments concerning this privacy statement and / or the processing of personal data you can contact us at the address or numbers mentioned in point 7.4 above.