Personal data protection

This notice refers to the processing of personal data by the operator PHARMANOVA DOO Obrenovac.

This notice refers to the processing of personal data by the operator PHARMANOVA DOO Obrenovac.

PHARMANOVA DOO Obrenovac processes personal data only of those data subjects with whom it comes into contact in order to conduct its business, either by collecting data directly from these persons, or through their employers, contractors, business partners or, where applicable, third parties.

Personal data are always processed by PHARMANOVA DOO Obrenovac in accordance with the principle
of restricting the retention period, to the minimal period of time during which the specific purpose of the company is fulfilled.

I. The main categories of personal data subjects and the types of personal data to which the rules on the processing of personal data by PHARMANOVA DOO Obrenovac refer, include, but are not limited to, are as follows:

  1. Employees and persons hired without employment, former employees and retirees 

PHARMANOVA DOO Obrenovac, processes the personal data of employees and persons hired without employment, as well as the personal data of former employees and retirees and their family members, primarily in order to enforce and comply with applicable regulations governing the handling of this type of data, including but not limited to labor regulations and records in the field of labor, old-age, disability, health and social insurance, tax and accounting regulations, occupational safety and health regulations, as well as relevant regulations governing data processing in the pharmaceutical industry and other related regulations. The data of employees and other hired persons is also processed to the extent necessary in order to conclude and execute an appropriate contract with these persons. Data of this category of persons is also processed on the basis of their consent whenever it is necessary for such consent to be obtained in accordance with the applicable regulations, i.e. on the basis of a legitimate interest, when such a legitimate interest exists.

  1. Persons who apply for employment, or hired without employment 

Data of persons applying for employment, or hired without employment or for an internship, are processed only to the extent necessary for the recruitment and selection processes of candidates to be carried out in an efficient manner, taking into account the interests of PHARMANOVA DOO Obrenovac and the candidate’s freedoms, rights and interests. Candidates who have not passed the selection process and whose data have been collected for this purpose are provided with all the rights they have under the applicable regulations.

  1. Persons who report adverse drug reactions

The personal data of persons who report adverse drug reactions are processed exclusively in accordance with the positive regulations, which includes the fulfilment of contracts with appropriate partners.

  1. Academic community

PHARMANOVA DOO Obrenovac, attains the consent from persons who constitute the academic community, for the processing of their personal data within the internal collections that are kept for cooperating and communicating with these persons. The consent of these persons is not required if the processing of their personal data is necessary for the execution of contracts concluded by these persons, as well as in order to comply with certain legal obligations applicable to PHARMANOVA DOO, or if the personal data of persons in this category is processed in certain situations based on a legitimate interest by PHARMANOVA DOO.

  1. Business associates and individuals hired by business associates – legal entities

In order to organize business, PHARMANOVA DOO collects personal data of both natural persons who act independently, and natural persons who are employed by business partners (legal entities) and potential business partners, or persons who are hired by them on another basis. The subject processing is performed both for the purpose of concluding these contracts, and for the purpose of their performance and fulfillment of all legal obligations that PHARMANOVA DOO has in this regard. If the contracting party is not a natural person but a legal entity that hired it, PHARMANOVA DOO will have a legitimate interest in processing personal data to the extent necessary for the contract to be performed. If certain personal data are not necessary for the conclusion and performance of a contract with a specific natural person who is the data subject, such personal data may be processed if PHARMANOVA DOO has a legitimate interest to perform specific processing, otherwise the performance of the contract would be difficult, and the processing does not jeopardize the rights or interests of the data subjects. The personal data of business associates and natural persons hired by business associates may also be processed if those persons have given valid consent for a purpose not related to the performance of the contract, and in accordance with applicable regulations

  1. Individuals with whom normal and appropriate business and partnership relations are maintained

PHARMANOVA DOO shall process the data of natural persons whom normal and appropriate business and partnership relations are kept with, both with individuals and persons hired or representing other legal entities, institutions or authorities, only to the extent necessary and appropriate for this purpose (sending to celebrations and events, sending promotional material), and in compliance with all principles of data processing, applicable regulations and internal acts.

  1. Persons entering the business circle of PHARMANOVA DOO

PHARMANOVA DOO has a legitimate interest in processing the personal data of all persons entering the business circle and business premises, regardless of their location, and to keep records of these visits in accordance with all applicable regulations, including but not limited to regulations governing personal security and video surveillance.

  1. Individuals participating in surveys and sweepstakes

Data of natural persons for the purpose of participating in certain prize games, surveys or questionnaires organized by PHARMANOVA DOO is processed either on the basis of legitimate interest or on the basis of the consent of these persons, depending on which categories of persons participate in a particular survey, what kind of personal data is processed and the like.

II Rights of persons with regard to the protection of personal data

  1. Right to notice of processing and insight

Employees and other data subjects have the right to be informed about the processing of their personal data and the right to access their personal data (which includes reviewing, reading, listening to data and taking notes).

  1. The right to receive a copy

Employees and other data subjects have the right to receive a copy of the data from PHARMANOVA.

  1. Rights of persons regarding the performed inspection

After the insight of the data subjects, they have the right to request from Pharmanova
a correction, amendment, update, deletion of data, as well as and interruption and temporary suspension of processing.

  1. Right to portability

The data subject may request PHARMANOVA to transfer personal data to another controller, when this is technically feasible, i.e. when the personal data, which are the subject of the transfer request, are in a structured and machine-readable format.

  1. Right to withdraw consent

In situations where the legal basis for the processing of personal data is the consent of the data subject, that person has the right to withdraw the consent at any time, in writing. Also, the data subject has the right to object to the processing of personal data for the purpose of direct marketing and to request a restriction on processing in some other cases. In the event that the data subject is not satisfied with Pharmanova’s response to the request for fulfillment of rights regarding the protection of personal data, they have the right to file a complaint to the Commissioner for Information of Public Importance and Personal Data Protection (

Person in charge of personal data protection in Pharmanova