Third Party (Vendor) Privacy Notice
Introduction
Ascend GmbH (“Company”, “Ascend”, “we”, “us”, or “our”), a subsidiary of Alkem Laboratories Limited, India, and based in Germany, is committed to protecting the privacy and security of personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (EU) (“GDPR”) and the German Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG).
This Third Party (Vendors) Privacy Notice (“Notice”) applies to individuals associated with Ascend’s third party vendors, suppliers, consultants, contractors, Wholesalers, Distributors, Retailers, service providers, and other business partners (collectively, “Vendors” or “you”) who provide goods or services to, or otherwise engage in business with Ascend. Ascend acts as the controller for the processing of Vendor personal data and determines the purposes and means of such processing in the context of its business relationships.
This Notice describes how Ascend collects, receives, stores, uses, discloses, shares, and otherwise processes personal data of such Third Party (Vendors) (“Vendor Personal Data”) in connection with its business operations, in accordance with applicable data protection laws.
I. Who is responsible for the processing of your personal data?
II. Which of your personal data do we collect and use?
III. On which legal basis do we process your personal data?
IV. Using and disclosing your personal information?
V. How can you access your personal data or ask for a correction?
VI. Which data protection rights do you have with regards to your personal data?
VII. Storage and security of personal information
VIII. Do we disclose your information outside Australia
IX. Contact us
I. Who is responsible for the processing of your personal data?
Ascend and its subsidiary or affiliated companies are responsible for the processing of your personal data. For the purposes of applicable privacy and data protection laws, the primary controller of your personal data is the Ascend subsidiary. Other Ascend group companies may also receive and process your personal data, either in the capacity of a controller or a processor, and this Notice applies equally to them.
II. Which of your personal data do we collect and use?
We collect and use personal data that we receive from you in the course of, or in connection with, your engagement or business relation with Ascend. In addition, and to the extent necessary for the purposes described in this Notice, we may process personal data obtained from publicly available sources or lawfully received from third parties (such as public registers, professional or commercial databases, or other legitimate sources).
The types of personal data we collect from you which includes, but not limited to:
1. Identity and Contact information
- Full Name
- Email ID
- Contact number
- Vendor SPOC’s Employer name
- Vendor’s Address
We recommend you do not provide special category of personal data unless specifically requested. We will only collect such data with your consent and handle it in accordance with this Privacy Notice.
Where possible, we will always try to collect personal data directly from you, for example, when you:
- meet with us in person;
- correspond with us in writing;
- provide your resume or other documents to us (including documents used to verify your identity); or
- request information or contact us through our website or by telephone.
We may also obtain your personal data from third parties we deal with, such as:
- Other Sources: Government and law enforcement agencies and service providers
When we collect personal data from third parties you refer to us, we will assume and you will ensure that you have made that third party aware of the referral and the purposes of collection, use, and disclosure of the relevant personal data.
All personal data collected from you is securely stored in the company’s internal cloud infrastructure. This ensures centralized management, controlled access, and compliance with data protection standards, safeguarding confidentiality and integrity at every stage of processing.
III. On which legal basis do we process your personal data?
Ascend processes your personal data for the purposes described in this Notice in accordance with the EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG), based on the following legal grounds, as applicable:
- Legitimate interests: Processing business-related contact details (such as email addresses and telephone numbers) of pharmacies and wholesalers for the purpose of establishing, managing, and maintaining business relationships, and for effective communication in the course of commercial operations, where such processing is necessary for the legitimate interests of Ascend and does not override your fundamental rights and freedoms.
IV. Using and disclosing your personal information?
The personal data you provide to us may be used for,
- Business contact management – Processing and maintaining business-related contact details, such as email addresses and phone numbers, of pharmacies and wholesalers to facilitate communication and support ongoing commercial relationships.
Your personal information may be used to comply with legal obligations, including disclosures to authorized entities such as law enforcement agencies, government bodies, and regulatory authorities, as required by applicable laws and regulations.
The personal data you provide to us may be disclosed to,
- Our employees;
- Our parent company (only in cases where such disclosure is required);
- German Government bodies;
- Our contracted service providers;
- Any entity to whom we are authorized or required by law to disclose your personal information (for example, law enforcement agencies and government and regulatory authorities;
The above entities may in turn disclose your personal data to other entities as described in their respective privacy policies or notices.
V. How can you access your personal data or ask for a correction?
How to seek access to and correction of personal information
If you wish to access your personal data, exercise any of your data protection rights, or have questions or concerns regarding how Ascend processes your personal data, you may contact the Data Protection Officer using the contact details provided by Ascend.
If you believe that your personal data has been processed unlawfully or are not satisfied with the response received, you have the right to lodge a complaint with the competent data protection authority in your country of residence, place of work, or where the alleged infringement occurred. You also have the right to seek judicial remedies where you consider that your data protection rights have been violated.
VI. Which data protection rights do you have with regards to your personal data?
- The right to access your data: You are entitled to ask Ascend for an overview of or to obtain a copy of the personal data we hold about you.
- The right to have your data corrected: You may request immediate correction of inaccurate or incomplete personal data we hold about you.
- The right to have your data erased: You may request that personal data be erased when it is no longer needed, where applicable law obliges us to delete the data or the processing of it is unlawful.
- The right to restrict data processing: You have the right to restrict the processing of your personal data in specific circumstances.
- The right to data portability: You have the right to receive your personal data in a structured, machine-readable format for your own purposes, or to request us to transfer it to a third party.
- The right to object to data processing: You have the right to object at any time, for reasons arising from your particular situation to our processing of your personal data based on the legitimate interests.
- The right to withdraw consent: Where Ascend has asked for your consent to process personal data, you may withdraw your consent at any time.
VII. Storage and Security of personal data
- The company will take reasonable steps to protect the personal information held from misuse, loss and from unauthorized access, modification or disclosure.
- Personal data that is no longer required will be destroyed or, where appropriate, de-identified. We may store information either physically or electronically.
- Electronic records shall only be accessible to employees who have been issued with a personal login identification and access. Employees will only be given a level of access appropriate to their duties.
- Paper records will be housed in areas restricted to Human Resources and Payroll staff, or employees accompanied by Human Resources or Payroll staff. The company will only store personal information for as long as necessary for the purpose for which the information was sourced and provided and / or as required by law. In such cases, the company will take reasonable steps to destroy or permanently de-identify an employee’s Personal Information.
VIII. Do we disclose your information outside EEA?
From time to time, Ascend may engage service providers located overseas to perform certain of its functions and activities. In the course of providing services to us, we may need to disclose your personal information to these service providers. If overseas service providers are engaged and personal information is sent overseas, we will take reasonable steps to ensure that our service providers are carefully chosen and have policies, procedures and systems in place to ensure your personal information is handled in accordance with the applicable data privacy laws.
IX. Contact us
If you have any questions about this privacy notice or your personal information, you can contact us at:
Email: privacy@ascend-de.eu
Postal Address:
Sebastian-Kneipp-Straße 41
60439 Frankfurt am Main
Germany