Information on the use of your personal data
In accordance with Articles 13 and 14 of Regulation (EU) 2016/679 ("GDPR")
We are committed to protecting your personal data and to complying with applicable data protection laws and, for this reason, we wish to provide you with up-to-date information on the processing of your personal data by: MENARINI STEMLINE ESPAÑA S.L.U. ("Menarini Stemline"), with registered office at Calle Alfonso XII, 587, 08918 Badalona (Barcelona), Spain, acting as Data Controller under the GDPR.
You may contact the Data Protection Officer ("DPO") of the Data Controller at the following email address: dpo@menarini.com.
1. What personal data do we process and for what purpose?
a. Personal data:
We may process your name, professional address, contact details (e.g. telephone number), academic qualifications, professional specialization/qualification, as well as any other data about you published on the Internet (e.g. publications, collaborations, social media posts, participation in clinical trials, etc.). Some of this personal data may be collected directly from you or from publicly accessible sources (e.g. clinicaltrials.gov), and other data may be received from our service provider, Veeva. Your personal data may be necessary for:
- i. the exchange of medical-scientific information, including, for example, the proactive exchange of data and knowledge relating to clinical practice, as well as objective, non-promotional information relating to Menarini Stemline's product portfolio or to activities relating to access to new products;
- ii. the performance of scientific information activities in respect of products authorized for marketing and distributed by Menarini Stemline.
The above-mentioned activities are carried out in person (e.g. face-to-face visits) and/or remotely (e.g. video calls) by Menarini Stemline personnel belonging to the Medical, Commercial or Access area.
Your personal data may be necessary for the performance of the relevant contract to which you are a party (legal basis: Article 6(1)(b) GDPR) and for compliance with a legal obligation applicable to Menarini Stemline (legal basis: Article 6(1)(c) GDPR). Additionally, your personal data may be necessary for the satisfaction of the following legitimate interests: maintaining our professional relationship with you, as well as for medical-scientific information, marketing and market research activities (legal basis: Article 6(1)(f) GDPR).
b. Information relating to visits by our staff:
Menarini Stemline may process the date and content of visits, preferred visiting hours, as well as any content (e.g. visual) that you select during the visit. In addition, Menarini Stemline may collect information about your level of knowledge of our products, your experience as a speaker at conferences, your affiliations/collaborations with other healthcare professionals, etc. This data may be necessary for the satisfaction of the following legitimate interests: maintaining our professional relationship with you, managing our staff, as well as carrying out medical-scientific information and marketing activities (legal basis: Article 6(1)(f) GDPR).
c. Information for the performance of contracts to which you are a party:
If a contract is entered into with you (e.g. lectures, consultancy services, participation in events, etc.), we will process your personal data to enable performance of the contract or for the application of pre-contractual measures (e.g. contact details, banking information, travel details, etc.) (legal basis: Article 6(1)(b) GDPR).
We may also process booking-related data connected with the performance of a contract (invoices, transfers made, etc.) in order to comply with our legal obligations and applicable tax regulations (legal basis: Article 6(1)(c) GDPR). If we carry out collaboration studies with you or process requests for therapeutic use, we may process your name, contact details, bank details and financial data.
d. Information for compliance with a legal obligation and/or to provide you with medical-scientific information:
In the case of adverse reaction reports or quality complaints regarding our products, Menarini Stemline may process your name and contact details (legal basis: compliance with a legal obligation and/or satisfaction of a public interest in the field of public health pursuant to Articles 6(1)(c) and 9(2)(i) GDPR) or – should you request it – medical-scientific information requested about our products, including by electronic means (legal basis: Article 6(1)(f) GDPR).
e. Additional information should you grant us your express consent:
Should you grant us your express consent, Menarini Stemline may send you scientific and/or promotional material relating to our products and services (e.g. published scientific articles, slide kits, etc.), as well as invite you to participate in professional training and update events by electronic means (e.g. email, etc.). In addition, Menarini Stemline may use the data referred to in points 1.a. to 1.c., together with your preferred communication channels (e.g. email) and your interaction with our emails and websites, to personalize our communications according to your needs and to assess their effectiveness. In this way, you will only receive relevant information about our products and training events, tailored to your interests and preferences (legal basis: your express consent, Article 6(1)(a) GDPR).
2. Recipients of your personal data
Your personal data may be processed by Menarini Stemline personnel to the extent necessary to fulfil the purposes of the processing. Your personal data may also be disclosed to Menarini Stemline's parent company, A. Menarini IFR Srl, Florence, as well as to other companies of the Menarini Group, including those established in countries outside the European Economic Area, for organizational, financial or internal management purposes.
We inform you that your personal data may be processed by external service providers (e.g. for the operation of our websites, for sending invitations and newsletters, etc.). In such cases, we will enter into the corresponding contractual safeguards to ensure that such personal data are processed in accordance with applicable regulations, respecting their confidentiality and integrity.
Menarini Stemline may use external service providers located in third countries outside the European Economic Area to process your personal data. Should your personal data be transferred to countries outside the European Economic Area, Menarini Stemline will implement the necessary mechanisms to ensure that your personal data are processed in such countries with an adequate level of protection, in particular by entering into standard contractual clauses approved by the European Commission with such third parties, or through a European Union adequacy decision. You may request a copy of the standard contractual clauses or of the safeguard(s) adopted at any time.
Should your personal data be disclosed to non-EU public authorities responsible for pharmacovigilance, it may not be possible to enter into standard contractual clauses approved by the European Commission. Where this is not possible, your personal data will be processed in accordance with the applicable regulations of the destination country, strictly for public-interest purposes in the field of public health. In this case, it may not be possible to exercise the rights of access, rectification or objection under the GDPR. In any event, whenever possible, your personal data will be communicated without your first and last name.
3. For how long will we retain your personal data?
In accordance with the principle of data minimization, your personal data will be retained for the period strictly necessary to fulfil the purposes for which it was collected, and will subsequently be retained in blocked form in order to comply with applicable legal obligations and to defend Menarini Stemline's interests against any potential liability claims arising from the processing, all in accordance with the limitation periods applicable to such legal or contractual obligations. Likewise, where the processing is based on your express consent, your data will be retained until such consent is withdrawn or your right to object is exercised.
4. Your rights as a data subject
You may contact us at any time at the address indicated above or by email:
- if you are a healthcare professional, at escustomerservice@stemline.com
- if you are a pharmacist, at privacypharmacists@menarinistemline.com
to exercise your rights of access, rectification, erasure, restriction of processing, data portability and objection, by written request accompanied by documentation proving your identity. We also inform you that you may withdraw your consent at any time, although such withdrawal will not affect the lawfulness of the processing carried out prior to such withdrawal.
Finally, you may contact our DPO at dpo@menarini.com to forward any query, complaint or request for additional information regarding how Menarini Stemline processes your data; you are also entitled to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos) (www.aepd.es). You can find the contact details of all European national data protection authorities at https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
Version: October 2024


