Privacy Policy


VRPharma recognizes that your privacy is important to you and cares about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, (“Our Site”), and will only collect and use personal data in ways that are described here, and in a manner consistent with our obligations and your rights under the law. Please read this Privacy Policy carefully and ensure you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must cease using Our Site immediately.

1. Definitions and Interpretation

1.1 In this Policy, the following terms shall have the following meanings:

  • “Account” means an account required to access and/or use certain areas and features of Our Site;
  • “Cookie” means a small file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14.
  • “Cookie Law” refers to the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.

2. Information About Us

2.1 Our Site is owned and operated by VRPharma, with a registered office at Francisco Grandmontage 1,2, 20018 San Sebastián, Spain.

2.2 Our VAT number is ESB04996492.

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and advise you to check the privacy policies of any such websites before providing any data to them.

4. What Are Personal Data

4.1. Personal data are defined under the General Data Protection Regulation (EU Regulation 2016/679) (“GDPR”) and the Data Protection Act 2018 collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
4.2. Personal data are, in simpler terms, any information about you that enables you to be identified. Personal data includes obvious information such as your name and contact details, but also includes less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. Your Rights

5.1. Under the Data Protection Legislation, you have a range of rights, which we are always fully committed to upholding:

  • The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to learn more or to ask any questions using the details in Part 15.
  • The right to access the personal data we hold about you. Part 13 tells you how to do this.
  • The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
  • The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of your personal data that we have. Please contact us using the details in Part 15 to find out more.
  • The right to restrict (i.e. prevent) the processing of your personal data.
  • The right to object to us using your personal data for particular purposes.
  • Rights regarding automated decision-making and profiling.

5.2. If you have any cause for complaint about our use of your personal data, you are entitled to lodge a complaint with the Information Commissioner’s Office. However, we would welcome the opportunity to resolve your concerns ourselves, so please contact us first, using the details in Part 15.

6. What Data Do We Collect?

6.1. Depending on your use of Our Site, we may collect some or all of the following personal and non-personal data (please also see Part 14 on our use of Cookies and similar technologies and our Cookie Policy):

  • Name;
  • Contact information such as email addresses and telephone numbers;
  • Demographic information such as postcode, preferences, and interests;
  • IP address;
  • Web browser type and version;
  • Operating system;
  • A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.

7. How We Use Your Data

7.1. Our use of your personal data will always have a legal basis, either because it is necessary for our compliance with a contract with you, because you have consented to our use of your personal data (e.g., by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:

  • To register you on Our Site;
  • To provide and manage your Account;
  • To provide and manage your access to Our Site;
  • To personalize and tailor your experience on Our Site;
  • To manage Our Site;
  • To manage our business;
  • To supply you with Our products and services (please note that we require your personal data in order to enter into a contract with you);
  • To manage payments for our products and services;
  • To personalize and tailor Our products and services for you;
  • To communicate with you;
  • For market research purposes;
  • To provide you with information by email or post that you have opted into (you may unsubscribe at any time).

7.2. With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message, or post with information, news, and offers on our products and services. You will not receive any unsolicited marketing or spam. We will constantly work to protect your rights fully and comply with our obligations under the Data Protection Legislation, and you will always have the opportunity to opt-out.
7.3. Third parties (including Google Analytics, PayPal, and YouTube) whose content appears on Our Site may use third-party Cookies, as detailed later in Part 14. Please refer to Part 14 for more information on controlling Cookies. Please be aware that we do not control the activities of such third parties, nor the data they collect and use, and advise you to check the privacy policies of any such third parties.
7.4. We will only use your personal data for the purposes for which it was originally collected, unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we use your personal data in this way, and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
7.5. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
7.6. Sometimes, when the law allows or requires us to, we may process your personal data without your knowledge or consent. This will only be done within the framework of the Data Protection Legislation and your legal rights.

8. How Long We Keep Your Personal Data

8.1. All personal data is processed and stored securely, for no longer than necessary based on the reasons for which it was first collected. We will fulfill our obligations and protect your rights under the GDPR at all times. For more details on security, please see section 9 below.

9. How and Where We Store or Transfer Your Personal Data

9.1. We only store or transfer your personal data within the European Economic Area (the “EEA”), which consists of all EU member states plus Norway, Iceland, and Liechtenstein. This means your personal data will be fully protected under data protection legislation, GDPR, and/or equivalent standards by law.
9.2. The security of your personal data is crucial to us, and to protect your data, we take significant steps, including:

  • Limiting access to your personal data to those employees, agents, contractors, and other third parties who have a legitimate need to know, ensuring they are subject to confidentiality duties;
  • Procedures for dealing with data breaches (accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your personal data), including notifying you and/or the Information Commissioner’s Office where the law requires it.

10. How We Share Your Data

10.1. We may sometimes contract with third parties to supply products and services on our behalf. These may include payment processing, delivery of goods and services, search engine facilities, advertising, and marketing. In some cases, these third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data is handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
10.2. We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymized and will not include any personally identifying data, or any anonymized data that can be combined with other data and used to identify you. We may from time to time-share such data with third parties such as prospective investors, affiliates, partners, and advertisers. The data will only be shared and used within the bounds of the law.
10.3. We may sometimes use third-party data processors that are located outside the European Economic Area (the “EEA”) (the EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR, as outlined above in Part 9.
10.4. If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way as set out in this Privacy Policy.
10.5. In limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11. How You Can Control Your Data

11.1. In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).

12. Your Right to Withhold Information
12.1. You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site, you may be required to submit or allow the collection of certain data.
12.2. You may restrict our use of Cookies. For more information, see Part 14 and Our Cookie Policy.

13. How You Can Access Your Data

13.1. If you want to know what personal data we have about you, you can request details of these personal data and a copy of them (where such personal data are stored). This is known as a “subject access request.”
13.2. All subject access requests should be made in writing and sent to the email or postal addresses provided in Part 15.
13.3. Normally, there is no charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests), a fee may be charged to cover our administrative costs in responding.
13.4. We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required, up to a maximum of six months from the date we receive your request. You will be kept fully informed of our progress.

14. Our Use of Cookies

14.1. Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience on Our Site and to provide and improve our products and services. When using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties besides us. Third-party Cookies are used on Our Site to enhance the experience of our visitors, for example, watching videos hosted on YouTube, making payments through PayPal, or seeing geographical locations on Google Maps. Additionally, Our site uses analytical services provided by Google Analytics, which also use cookies. Website analytics refers to a set of tools used to collect and analyze usage statistics, enabling us to better understand how people use Our Site. For more details, please refer to our Cookie Policy.

15. How to Contact Us

15.1. To contact us about anything related to your personal data and data protection, including making a subject access request, please consider using the contact methods provided on Our Contact page.

16. Changes to Our Privacy Policy

16.1. We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
16.2. Any changes will be immediately posted on Our Site and are deemed to be accepted by you on your first use of Our Site following the amendments. We recommend that you check this page regularly to keep up-to-date.

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