Your personal data

1. Data Controller

This Privacy Policy (« Privacy Policy ») describes the processing of personal data by Aquilon Pharmaceulticals S.A (« Aquilon Pharma »), data controller established in Rue Porte de Lorette 78, 4600 Visé, registered under the company identification number BE 0540.870.218 and who appointed Nina Demianoff in charge of the data processing. This person can be reached through the following email address: dataprivacy@aquilonpharma.com

We value your trust and wants to make sure that you understand our policies and practices regarding data protection. Therefore, we encourage you to read this Privacy Policy. In addition to the privacy practices set out in this Privacy Policy, we have Terms of Use which incorporate the terms of this policy. Our Terms of Use can be read here.

This Privacy Policy is applicable to all products and services offered by Aquilon Pharma.

By sharing with Aquilon Pharma personal data, you explicitly declare to have red this Privacy Policy carefully and you agree with all its terms. More precisely, you accept that Aquilon Pharma processes (collect, keep or use) your data for the purposes defined further.

Our website address is: https://aquilonpharma.com.

2. Personal data we collect and why we collect it

EU Privacy Notice: We confirm that any Personal Information of data subjects processed in the context of our activities in the EU will be carried out in accordance the Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data – General Data Protection Regulation (“GDPR”).

The General Data Protection Regulation (« GDPR ») defines « Personal Data » as data that identifies you as an individual or relates to an identifiable natural individual.

« Identifiable natural individual » is defined as one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

As part of its activities, AquilonPharma may have to collect personal data of its clients, employees, providers, sub-contractors (and their eventual own sub-contractors), prospects, companies/individuals, part of its professional network and their respective employees or any other relevant contact person.

These personal data can be, among others, names, surnames, phone number, addresses, email addresses, company name, company location, work title, etc. as well as any other information shared spontaneously by the concerned person.

Additionally, when visitors leave messages on the site we collect the data shown in the contact form, and also the visitor’s IP address and browser user agent string to help spam detection.

The website of Aquilon Pharma (https://aquilonpharma.com) is using cookies (see Cookies Policy)

3. How personal data are collected and kept

Personal data are collected through:

• The contact form on the website: https://aquilonpharma.com/en/contact/
• By email;
• By phone;

An anonymized string created from your email address (also called a hash) may be provided to the

Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/.

The shared personal data are kept on the server of Aquilon Pharma its access is limited to certain users and via the use of secured passwords.

4. Data processing purposes

The personal data is collected by Aquilon Pharma in order to provide services/products under contractual obligations but also to manage customers, billings, for promotional purposes and to fulfill legal, accounting and regulatory obligations/requirements.

5. Legal grounds for data processing

The legal grounds for the data processing are the execution of a contract, consent of the concerned person, respect of legal obligations/requirements and/or in the best legitimate interest of Aquilon Pharma.

6. Personal data recipient

Aquilon Pharma will keep and process itself the personal data collected in order to carry out the data processing purposes.

Nonetheless, within the framework of these purposes, it is possible that personal data have to be shared with public authorities, accountants, auditors, lawyers, debt collection company, IT service provider or any other sub-contractor of Aquilon Pharma.

It is possible that these entities are not located inside the European Economic Area (« EEA »). In that case, the personal data will only be shared with third-party countries disposing of an adequate level of protection.

If necessary, the personal data could be shared with other third-parties in the context of, for example, a restructuration of Aquilon Pharma, transfer of activity, liquidation or bankruptcy, injunction or to fulfill specific legal obligations.

However, Aquilon Pharma will make sure that these people/companies/entities will only have access to the specific data needed and that they will not process unnecessary data.

7. Retention period

Aquilon Pharma will keep the personal data shared with it as long as it is needed for the processing purposes.

To determine the appropriate time limit, the nature, the sensibility of the personal data and its purpose are taken into account. The necessity to comply with legal and regulatory obligations are also considered.

8. Security measures

Aquilon Pharma undertakes appropriate security measures, both technical and organizational, in order to prevent the destruction, lost, falsification, modification, unauthorized access by third parties or communication to unauthorized third parties of the personal data.

Therefore, Aquilon Pharma arranged, inter alia, the followings:

• use of secured passwords by employees and executives;
• list of affiliations (DJM, Nina)
• incorporation of specific data confidentiality clauses in contracts and terms of employments;
• frequent update of the PC with security patches and antivirus;
• regular backups of important data.

9. Rights of data subjetcs

9.1 right of access, rectification, erasure and restriction

You have the right to ask Aquilon Pharma to grant you access to your personal data and to ask for a restriction of its use.
As required by the legal terms of the GDPR, you also have the possibility to ask for the erasure of your personal data and to ask for their limitation.

You acknowledge that if you refuse to share personal data or if you ask for the erasure of your personal data, Aquilon Pharma may not be able to provide certain services to you anymore.

9.2 right to object

You have the right to object against the use of your personal data for legitimate and compelling grounds.
Furthermore, you also have the right to object against the use of your personal data for marketing purposes. In that case, you do not need to invoke any ground.

9.3 right to data portability

You have the right to receive the personal data you provided to Aquilon Pharma in a structured, commonly used and machine-readable format (such as PDF format) and to transmit those data to another data controller.

9.4 right to withdraw your consent

If the data processing is based on your prior consent, you have the right to withdraw this consent.

9.5 exercise your rights

You can exercise your rights by getting in contact with Aquilon Pharma by email at the following email address: dataprivacy@aquilonpharma.com or at the following postal address « Quai de la Boverie 59, in 4020 Liège », provided that you annex a copy, front and back, of your identity card.

9.6 automated individual decision-making and profiling

The processing of your personal data does not include any profiling and no individual decision will be based solely on automated processing by Aquilon Pharma.

9.7 right to lodge a complain

Without any prejudice to resort to a civil court, you have the right to lodge a complain at the Data Protection Authority : Autorité de protection des données, rue de la presse 35, 1000 Bruxelles, Tél.: +32 (0)2 274 48 00, Fax +32 (0)2 274 48 35, email : contact@apd-gba.be.

10. Modifications

Modifications can be made by the Data Protection Officer at any time to this personal data Privacy Policy. Any changes to the Privacy Policy will become effective when the revised Privacy Policy is made available on the Website. Please read the content of the Privacy Policy regularly before using the Website, as your continued use of the Website after any changes to the Privacy Policy means that you accept the revised Privacy Policy.

Last Update : September 2020

This Privacy Policy is established without prejudice to the rights and obligations recognized in the part of Aquilon Pharma under the applicable provisions, such as those of the General Data Protection Regulation.