The Pharma Navigator
Last updated: [insert publication date]
This policy explains how Navigator Media Ltd collects, uses and protects personal information when you use The Pharma Navigator website, create a free account, subscribe to our newsletters, contact us or work with us. It also explains your choices and data protection rights.
Who we are
The Pharma Navigator is operated by Navigator Media Ltd, a company registered in England and Wales under company number 15251347. Our registered office is The Steam Mill, Steam Mill Street, Chester, Cheshire, CH3 5AN, United Kingdom.
We are the controller responsible for the personal information described in this policy. Our Information Commissioner’s Office (ICO) registration number is ZB848813.
Email: news@thepharmanavigator.com
Telephone: +44 (0)1244 953 043
Data Protection Officer: paul@gdprassist.co.uk
Where we process information solely on a client’s instructions to provide marketing support, we act as that client’s processor. The client’s privacy notice explains its use of that information.
Information we collect
Depending on how you interact with us, we collect:
- Contact and professional details, such as your name, email address, telephone number, organisation, job title, industry and country.
- Account information, including your registration details, authentication information, account activity and preferences.
- Subscription and marketing information, including the newsletters you request, your interests, consent records and unsubscribe preferences.
- Correspondence, including enquiries, editorial submissions, feedback and records of our communications.
- Technical and usage information, such as your IP address, browser and device information, pages visited, referring websites and cookie identifiers. Optional tracking is subject to the choices explained below.
- Business records, such as details of advertising or supplier relationships, contracts and invoices. These may contain personal information about business contacts or sole traders.
- Recruitment information if you enquire about a role, such as your contact details, CV and application.
We collect information directly from you, automatically through your use of our services, and where relevant from your organisation, our service partners or public professional sources, such as company websites and published press releases. Where we obtain information indirectly, we provide any additional privacy information required by law.
Required fields are identified when we collect information. If you do not provide information needed to create an account or deal with a request, we may be unable to provide that particular service. Optional marketing consent is not required to create an account.
How we use information and our lawful bases
Under UK data protection law, we must have a lawful basis for using personal information. The basis depends on the purpose.
Accounts and requested services
We use registration and account information to create and manage your account, authenticate access and send necessary service messages. Our basis is performance of our agreement with you, or steps you ask us to take before entering it. We rely on our legitimate interests in operating a secure service to prevent misuse and investigate security incidents.
Enquiries and editorial activity
We use contact details and correspondence to respond to enquiries, assess submissions and manage editorial relationships. We rely on our legitimate interests in running our publication and communicating with readers and contributors. Where we enter an agreement with you personally, necessary processing is based on that agreement.
If we publish professional information about an individual in our reporting, our legitimate interest is informing readers about pharmaceutical industry developments. We consider the individual’s rights and any applicable rules governing journalistic processing.
Newsletters and marketing
We use your consent to send newsletters and other email marketing you choose to receive. Where the law permits us to contact corporate business subscribers without consent, we may rely on our legitimate interests in promoting relevant publishing and advertising services. We assess those interests against your rights and reasonable expectations.
We obtain consent where it is legally required, including for electronic marketing to individuals, sole traders and certain partnerships unless a lawful exception applies. Legitimate interests do not override these requirements.
Business relationships
We use business contact details to manage relationships with advertisers, sponsors, clients and suppliers. We rely on our legitimate interests in maintaining those relationships. Where you contract with us personally, we use information necessary to perform that contract or take requested steps before it. We rely on legal obligations for records we must keep by law.
Analytics and optional tracking
With your consent, we use optional analytics and marketing technologies to understand website use and measure campaigns. This includes personal information collected through those technologies. Necessary security and service administration are based on our legitimate interests in maintaining the website.
Recruitment and legal matters
We use information from recruitment enquiries to take steps towards a possible employment contract at your request. We provide further privacy information as recruitment progresses. We process information to meet legal obligations where required, and rely on our legitimate interests to establish, exercise or defend legal claims.
Where we rely on legitimate interests, you can object as explained below. Where we rely on consent, you can withdraw it at any time without affecting the lawfulness of earlier processing.
Your newsletter and marketing choices
You can unsubscribe using the link in our marketing emails or by contacting us. You have an absolute right to object to use of your personal information for direct marketing, including related profiling. We will stop that use when you object.
Our newsletters and promotional emails may include advertising, sponsored content and information about industry partners. Receiving these messages does not itself give those partners permission to send you their own marketing.
Creating an account, accepting our Terms and Conditions or reading this policy does not constitute marketing consent. Account and security messages may still be necessary after you unsubscribe from marketing. Closing an account and unsubscribing from newsletters are separate choices; you can ask us to do both.
We may retain a minimal suppression record, such as your email address and opt-out status, to ensure that we continue to respect your choice.
Sensitive information
We do not routinely request special category information, such as information about health or religious beliefs. Please avoid including unnecessary sensitive information in enquiries or editorial submissions.
If we organise an event and need dietary or accessibility information that reveals sensitive information, we explain why it is needed and obtain explicit consent where appropriate. We use it only for the stated purpose and retain it only as long as needed to make and administer the arrangements.
Who we share information with
We share relevant information with suppliers supporting our website hosting, account administration, IT, customer relationship management, email distribution, analytics and other business services. Our providers include Microsoft Office 365 and SharpSpring. Suppliers processing information on our behalf must act under appropriate contractual instructions and safeguards.
We also share relevant information with Orientation Marketing Ltd in the UK and its operations in Finland and the USA to deliver our services. Our basis is our legitimate interest in coordinating service delivery, subject to your rights and any consent required for the particular activity.
If a sponsored resource, webinar or event involves sharing your details with a sponsor or organiser, the collection form will identify the recipient and explain the purpose and lawful basis before you submit your details. We obtain separate consent where required for the recipient’s own marketing. Its privacy notice applies to its subsequent use of the information.
We may also share information with professional advisers, regulators, courts or law enforcement where required by law or where necessary and lawful to protect rights or address suspected wrongdoing. Email and social media providers process information when you communicate through their services, under the arrangements applicable to those services.
International transfers
We primarily process information in the UK, and our website hosting provider processes data in the UK. Some of our suppliers and partners also process information in the USA and Finland.
For restricted transfers outside the UK, we use an applicable UK adequacy arrangement or appropriate contractual safeguards. Our arrangements include:
- Microsoft Office 365: standard contractual clauses for transfers to the USA.
- SharpSpring: the UK Extension to the EU–US Data Privacy Framework where the receiving organisation’s certification is current and covers the transfer. If that route is unavailable, an alternative lawful safeguard is required.
- Orientation Marketing’s Finnish operations: the UK’s adequacy arrangements for the European Economic Area.
- Orientation Marketing’s US operations: a UK International Data Transfer Agreement.
Contact our Data Protection Officer for more information about overseas processing or a copy of relevant safeguards, subject to necessary redactions.
How long we keep information
We keep information only for as long as needed for its purpose, taking account of legal requirements, complaints and potential claims. We review records and delete or anonymise information when it is no longer needed.
Our default maximum periods for enquiry records, client and supplier contact records, and direct marketing contact records are seven years after our last contact with you. These are maximum periods, not a reason to retain every record for seven years. An unsubscribe or marketing objection takes effect when made; it does not wait for that period to expire.
We keep account information while your account remains open and as needed to provide the service. Following closure, we delete or anonymise information that is no longer needed, retaining only records needed for outstanding matters, legal requirements, security or claims. We review inactive accounts according to whether there is a continuing need to retain them.
Unsuccessful recruitment enquiries are normally retained for up to six months after our last contact concerning the enquiry. Any further recruitment retention is explained separately.
We keep consent records and minimal suppression records for as long as needed to demonstrate and respect your choices. Technical logs are retained only as needed to operate the service and investigate security issues. Cookie lifetimes are set out in our cookie information. Relevant records may be retained longer where a legal obligation or an active dispute requires it.
Cookies and similar technologies
We use essential technologies to operate the website, maintain account sessions and remember privacy choices. We also use optional technologies for analytics and marketing, including Google Analytics. Google Tag Manager manages the deployment of website tags; the cookies and information involved depend on the tags enabled through it.
We ask for consent before using optional analytics or advertising cookies and similar technologies. You can accept or reject optional categories and change your choices through [insert link to Cookie settings]. Refusing optional technologies does not prevent access to the main website content, although some optional embedded features may remain unavailable until you enable them.
[Insert the launch cookie inventory, or a link to it, identifying each cookie or similar technology, its provider, purpose, category and duration.]
Your browser also lets you manage cookies. Blocking essential cookies may affect sign-in or other requested functions. External video, podcast and social media services have their own privacy information and may use their own technologies when you enable or interact with them.
Security
We use appropriate technical and organisational measures to protect personal information, including encrypted connections, access controls, staff confidentiality obligations and contractual protections for suppliers. No online service can guarantee absolute security. Please keep your account credentials confidential and contact us promptly if you suspect unauthorised access.
Your rights
Depending on the circumstances, you may ask us to:
- Give you access to your personal information and a copy of it.
- Correct inaccurate or incomplete information.
- Delete information where there is no lawful reason to keep it.
- Restrict how we use information.
- Stop processing based on legitimate interests, taking account of your particular situation.
- Provide information you supplied in a portable format, where processing is automated and based on consent or a contract.
You can also withdraw consent and object to direct marketing at any time. Some rights have legal conditions or exceptions; if we cannot fulfil a request, we will explain why. We do not make solely automated decisions about you that produce legal or similarly significant effects.
Contact news@thepharmanavigator.com or our Data Protection Officer to exercise your rights. We may need proportionate information to verify your identity. We normally respond within one month, subject to any extension or pause permitted by law, which we will explain. Requests are normally free; we charge a reasonable fee or refuse a request only where the law permits, including where it is manifestly unfounded or excessive.
Complaints
If you have a concern about our use of your information, contact us or our Data Protection Officer using the details above. We will acknowledge your complaint within 30 days, investigate appropriately, keep you informed and provide an outcome without undue delay.
You also have the right to complain to the ICO at any time. Visit https://ico.org.uk/make-a-complaint/ or call 0303 123 1113. You do not have to complete our complaints process before exercising that right.
Other websites and policy updates
Links to external websites lead to services with their own privacy policies. Please review those policies before providing information.
We may update this policy to reflect changes in our services or legal requirements. The date above shows the latest version. We will bring material changes to your attention where appropriate and obtain fresh consent where required.
