Privacy Notice on the Processing of Personal Data in Connection with the Use of the Pharmapool Kft. Website, Product Information Enquiries, Quality Complaints and Pharmacovigilance Reports
Effective date: 5 June 2026
Document version: v1.0
In this Privacy Notice, Pharmapool Kft. provides visitors to its website and natural persons who contact the company with information about its processing of personal data, in accordance with the information requirements laid down in Articles 13 and 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council (the General Data Protection Regulation, hereinafter: the “GDPR”).
In particular, this Notice describes:
Pharmapool Kft. processes personal data solely for specified, explicit and lawful purposes, to the extent necessary and in accordance with the legislation applicable to the processing.
In the course of in-person professional contact with healthcare professionals, Pharmapool Kft. may use a separate privacy notice and consent form, which it makes available to data subjects when personal contact is established.
Name of data controller: Pharmapool Kft.
Registered office: 1134 Budapest, Róbert Károly körút 59, 1. em., Hungary Company registration number: 01-09-272143
E-mail: info@pharmapool.hu
Website: https://www.pharmapool.hu
Please note that Pharmapool Kft. has not appointed a data protection officer pursuant to Article 37 of the GDPR.
Pharmapool Kft. – Privacy Notice
Contact person for data protection matters:
Name: Anar Zeveg
Position: Data Protection Contact
E-mail: anar.zeveg@pharmapool.hu
Data subjects may also contact the Data Protection Contact with any questions concerning the processing of their personal data, the exercise of their rights, or the data protection practices of Pharmapool Kft.
When you visit the Pharmapool Kft. website, your browser automatically transmits certain technical data to the server that operates the website. Processing these data is technically necessary for the website to be displayed and operate securely and for potential errors, unauthorised access or misuse to be detected.
The categories of data processed include in particular:
Purpose of processing: to make the website available, ensure its secure and proper operation, identify technical errors, and prevent and investigate misuse.
Legal basis for processing: the legitimate interest of Pharmapool Kft. in operating the website securely and protecting its IT system.
Retention period: Pharmapool Kft. and/or its hosting provider process technical log data associated with operation of the website for as long as necessary to ensure secure operation, remedy errors, and prevent and investigate misuse. In the event of a security incident, suspected misuse or the establishment, exercise or defence of legal claims, the data may be retained for such additional period as is necessary.
If you contact Pharmapool Kft. by e-mail or via any of the contact channels available on the website, the company will process the personal data you provide to respond to and handle your enquiry.
The categories of data processed are:
Pharmapool Kft. – Privacy Notice
Purpose of processing: receiving, processing and responding to the enquiry, maintaining contact, and clarifying any legal or business matters.
Legal basis for processing:
Retention period: Pharmapool Kft. processes personal data provided by e-mail or through other contact channels for as long as necessary to respond to the enquiry and handle the matter. Where an enquiry is relevant from a legal, contractual, business or regulatory perspective, the data may be retained for the applicable limitation period necessary for the establishment, exercise or defence of legal claims. Pharmapool Kft. periodically reviews the data contained in enquiries and deletes data that are no longer necessary for further processing.
Pharmapool Kft. may handle medical or product information enquiries, quality complaints and pharmacovigilance or drug safety reports concerning its products; products it represents, distributes or handles as part of its wholesale activities; and products associated with its contractual partners.
In some cases, Pharmapool Kft. may act as a data controller in its own right, while in other cases it may act as a data processor on behalf of a marketing authorisation holder, contractual partner or client. The applicable role is determined by the product concerned, the nature of the report and the governing agreement or safety data exchange agreement.
6.1. Purpose of processing
The purposes of processing are:
6.2. Categories of personal data processed
Depending on the nature of the enquiry or report, the categories of data processed may include in particular:
Personal data relating to the reporter or the person making the enquiry:
Personal data relating to the person, consumer or patient concerned:
Pharmacovigilance reports may also contain data concerning health, which constitute a special category of personal data under the GDPR.
6.3. Legal basis for processing
Depending on the nature of the report or enquiry, the legal basis for processing is:
Pharmapool Kft. processes personal data contained in reports only to the extent necessary for the relevant purpose. Where compatible with the handling of the report and compliance with applicable legal obligations, Pharmapool Kft. removes, masks, limits or pseudonymises personal identifiers.
6.4. Recipients
Where necessary, Pharmapool Kft. may disclose data relating to product information enquiries, quality complaints and pharmacovigilance reports to:
Personal data are disclosed to recipients only to the extent necessary in each case. 6.5. Retention period
The retention period for pharmacovigilance, drug safety and product quality documentation is determined with regard to the product concerned, the nature of the report, the applicable legislation and regulatory requirements, and the relevant safety data exchange agreement.
As a general rule, pharmacovigilance documentation may be subject to a longer retention period, as it must be retained to meet drug safety requirements, ensure traceability and regulatory auditability, and handle any follow-up reports.
Where Pharmapool Kft. acts as a data processor, the retention period is determined by the controller’s instructions, the governing agreement and the applicable pharmacovigilance obligations.
The Pharmapool Kft. website may use cookies that are necessary for its operation. Cookies are short text files that a website may place on the user’s device.
Strictly necessary cookies support the proper and secure operation of the website, session management and essential technical functions. The data subject’s consent is not required for the use of these cookies.
If Pharmapool Kft. uses analytical, statistical, marketing or other non-essential cookies on the website, they are placed only with the data subject’s prior consent. The data subject may withdraw or modify consent at any time through the cookie settings available on the website.
Detailed information on the types, purposes, providers and lifetimes of cookies, and on how consent may be given, modified and withdrawn, is available in the separate Cookie Notice.
In the course of its processing activities, Pharmapool Kft. may engage IT, hosting, e-mail, cloud file-storage, document-management or other service providers. Pharmapool Kft. selects these service providers and contractors with due care and reviews them as necessary. Data processors may process personal data solely on the documented instructions of Pharmapool Kft. and under a data processing agreement.
Data processors and service providers currently engaged by Pharmapool Kft.: Service provider Address / registered office Nature of service
Rackhost Zrt. 1132 Budapest, Victor Hugo utca 18–22, Hungary;
registered office: 6722
Szeged, Tisza Lajos körút 41,
Hungary
Sync.com Inc. 105–155 Gordon Baker Road, Toronto, ON M2H 3N5,
Canada
e-mail services, website hosting and server-side logging
cloud storage, file storage, backup and related IT services
If Pharmapool Kft. engages an external website developer, maintenance provider, analytics provider or other data processor in the future, it will update this Notice accordingly.
Pharmapool Kft. does not sell, lease or otherwise make data subjects’ personal data available to third parties for their own purposes.
Pharmapool Kft. uses the cloud storage services of Sync.com Inc. Use of the service may involve the transfer of personal data outside the European Economic Area to Canada.
The European Commission has adopted an adequacy decision in respect of commercial organisations in Canada; accordingly, transfers to Canada may take place pursuant to Article 45 of the GDPR.
If Pharmapool Kft. engages a service provider in the future whose services involve transfers to another third country, Pharmapool Kft. will ensure an appropriate transfer basis or safeguards in accordance with Chapter V of the GDPR.
Pharmapool Kft. protects personal data against unauthorised access, alteration, transfer, disclosure, erasure or destruction by implementing appropriate technical and organisational measures.
These measures include in particular:
Personal data may be accessed only by employees, contractors and data processors who require such access in order to perform their duties.
Under the GDPR, data subjects have the following rights:
11.1. Right of access
The data subject has the right to obtain confirmation as to whether or not personal data concerning them are being processed and, where that is the case, to obtain access to the personal data and information concerning the processing.
11.2. Right to rectification
The data subject may request the rectification of inaccurate personal data concerning them and the completion of incomplete personal data.
11.3. Right to erasure
The data subject may request the erasure of their personal data where the conditions laid down in the GDPR are met. The right to erasure may be restricted in respect of pharmacovigilance data or data that must be retained by law.
11.4. Right to restriction of processing
The data subject may request restriction of processing where the conditions laid down in the GDPR are met.
11.5. Right to data portability
Where processing is based on consent or on a contract and is carried out by automated means, the data subject may have the right to receive personal data concerning them, which they have provided, in a structured, commonly used and machine-readable format.
11.6. Right to object
The data subject may object to the processing of their personal data where processing is based on the legitimate interests of Pharmapool Kft. or a third party. In such cases, the objection may be raised on grounds relating to the data subject’s particular situation.
Where personal data are processed for direct marketing purposes, the data subject may object at any time and without giving reasons. In that case, Pharmapool Kft. will no longer process their personal data for direct marketing purposes.
11.7. Withdrawal of consent
Where processing is based on consent, the data subject has the right to withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
11.8. Automated decision-making
In connection with use of the website, Pharmapool Kft. does not carry out automated decision making that produces legal effects concerning the data subject or similarly significantly affects them.
A data subject may submit a request concerning their personal data using the following contact details:
E-mail: info@pharmapool.hu
Data Protection Contact: anar.zeveg@pharmapool.hu
Postal address: 1134 Budapest, Róbert Károly körút 59, 1. em., Hungary
Pharmapool Kft. will respond to a data subject request without undue delay and in any event within one month of receipt. Where necessary, having regard to the complexity and number of requests, this period may be extended in accordance with the GDPR.
If a data subject considers that the processing of personal data by Pharmapool Kft. infringes the GDPR or other data protection legislation, they may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information.
Hungarian National Authority for Data Protection and Freedom of Information Registered office: 1055 Budapest, Falk Miksa utca 9–11, Hungary
Postal address: 1363 Budapest, P.O. Box 9, Hungary
E-mail: ugyfelszolgalat@naih.hu
Telephone: +36 (1) 391 1400
Official gateway: short name: NAIH, KR ID: 429616918
Website: www.naih.hu
The data subject also has the right to seek a judicial remedy. At the data subject’s option, proceedings may also be brought before the court having jurisdiction over their place of residence or temporary residence.
Pharmapool Kft. reserves the right to amend this Privacy Notice from time to time, in particular in the event of changes in legislation or regulatory practice, changes to the operation of the website, or the introduction of a new processing activity.
The current version of the Privacy Notice is available on the Pharmapool Kft. website.
