Policies - Flynn Forum

Legal Disclaimer

Flynn Pharma has made every effort to ensure that the information given at this website is up to date and accurate and not misleading in any way. Occasionally services and materials specifications may change or vary dependent on any third-party supplier Flynn Pharma uses. When this occurs, Flynn Pharma makes every effort to update information at this website, so long as we ourselves are informed of changes by our suppliers. Flynn Pharma accepts no legal nor financial responsibility resulting from changes in third-party supplier product and service information. Any views or opinions which may be occasionally expressed at this website are done so without prejudice and may or may not be the opinion of Flynn Pharma at the time of publication.

Copyright

Unless otherwise stated all materials (pictures and text content) at this website are the intellectual property of Flynn Pharma, or are used with our clients’ permission, or have been acquired for use under paid licence by its web design company and may not be copied, distributed, or otherwise disseminated without the written or authorised verbal permission of Flynn Pharma. Flynn Pharma has made every effort to ensure that all materials appearing on this site, including text and pictures are free from third party copyright. If any text or pictures have inadvertently been used that are copyright material Flynn Pharma will remove immediately any such items if contacted by the copyright owner. Flynn Pharma accepts no legal or financial responsibility should any such event inadvertently occur.

Privacy Policy

Flynn Pharma Limited (“We”) are committed to protecting and respecting your privacy.
This policy (together with our terms of use and any other relevant documents) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 2018 (the Act), the data controller is Flynn Pharma Limited of Hertlands House, Primett Road, Stevenage, Hertfordshire, SG1 3EE.

INFORMATION WE COLLECT FROM YOU
We will collect and process the following data about you:

Information you give us.
This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, address, e-mail address and phone number.

Information we collect about you.
With regard to each of your visits to our site we will automatically collect the following information:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

Information about your visit.
Including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed; page response times, download errors, duration of page visits, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.

Information we receive from other sources.
This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

USES MADE OF THE INFORMATION
We use information held about you in the following ways:

Information you give to us. How we will use this information:
to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
to notify you about changes to our service;
to ensure that content from our site is presented in the most effective manner for you and for your computer;

to comply with the laws and regulations that pharmaceutical companies are obligated to on post marketing surveillance.

Personal data is processed lawfully and according to the data protection laws. We may rely on the legal basis of consent, legitimate interests or contractual obligations. If your Personal Data is processed by relying on your consent then you may withdraw consent provided by you at any time by contacting us at events@flynnpharma.com.

Information we collect about you. We will use this information to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. Your information will allow us to improve our site to ensure that content is presented in the most effective manner for you and for your computer and also as part of our efforts to keep our site safe and secure.

Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Data Retention. How long we keep your data:
We do not keep your Personal Data for longer than necessary. Personal Data is kept for the purposes of processing it, legal or compliance requirements.

DISCLOSURE OF YOUR INFORMATION
Your personal information will be shared with:

Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
Selected third parties including:
business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
analytics and search engine providers that assist us in the improvement and optimisation of our site;
credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

We will disclose your personal information to third parties:

In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If Flynn Pharma Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation and other agreements; or to protect the rights, property, or safety of Flynn Pharma Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It will be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. However, your information may also be transferred within or outside the EEA where privacy laws may be less strict than in the UK. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our or third party secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at medinfo@flynnpharma.com.
Our site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Children
Our site is directed at an adult audience (such as healthcare professionals, investors and individuals seeking information about Flynn Pharma and healthcare products). We do not knowingly collect information from or about children.

Access to information
The Act gives you the right to access information held about you and a range of your rights that can be exercised in accordance with the Act:

Right to be informed,
Right to request access to your Personal Data,
Right to request any inaccuracies in your information to be corrected free of charge,
Right to be forgotten,
Right to restriction of processing,
Right to data portability,
Right to object to processing of your Personal Data,
Right related to not being subject to automated decision making and profiling

You can exercise these rights at any time by contacting us by sending an e-mail to medinfo@flynnpharma.com.

You can make a complaint
You have the right to lodge a complaint with the supervisory authority for data protection in the UK, if you consider that the processing of Personal Data relating to you has been infringed.

Changes to our privacy policy
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Questions, complaints and contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to medinfo@flynnpharma.com.
Flynn Pharma Ltd – All rights reserved, Privacy Policy, Legal Terms and Cookie Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

You have the right to contact The Supervisory Authority in the UK:

Information Commissioner Office (ICO)
Contact Information: https://ico.org.uk/global/contact-us/
Address: Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline: 0303 123 1113

Transfers of Value Policy

This privacy notice applies to all personal data relating to transfers of value (payments or benefits in kind) made by us, Flynn Pharma Ltd, to healthcare professionals and other relevant decision makers, hereafter called Covered Individuals.

In this notice when you see the words, “we”, “us, “our” or “Flynn Pharma Ltd”, it refers to Flynn Pharma Ltd. Where you see the words “you” it refers to Covered Individuals to whom we have made a transfer of value.

Flynn Pharma Ltd is a company that distributes branded and generic medicines. Flynn Pharma is a company established in 1994. We are the data controller and are responsible for your personal data.

What are personal data?

In this notice the words, “personal data” mean any information that identifies or may identify you, for example, your name, address and place of work. It also includes transfers of value/payments made to you by Flynn Pharma Ltd for activities/contracted services that you have engaged in with us.

The data we collect about you

The following categories of personal data are or may be collected and processed by Flynn Pharma Ltd about you:

Identity Data – your title, full name, specialty, role, principal practicing address
Optional Data for Disclosure UK – email address, third party IDs (where applicable);
Transfers of Value – The amount (whether in payment or benefit in kind) received by you from us and details of the related activities for which you received the Transfers of Value

How we collect your data

We collect your personal data when the transfer of value is made by us to you and during the course of the activities you undertake with us in respect of the transfer of value.

For what purpose do we use your data?

We are undertaking this to comply with the Association of the British Pharmaceutical Industry (“ABPI”)’s Code of Practice for the Pharmaceutical Industry (the “Code”).

We collect information about the transfers of value that you have received from us so that we can comply with our obligations under the Code and in particular the requirement that “companies must document and publicly disclose annually certain transfers of value made directly or indirectly to health professionals, other relevant decision makers… located in Europe”.

We collect and record your personal data for publication on Disclosure UK, the publicly accessible database managed by the ABPI that shows transfers of value from pharmaceutical companies that are signatories or have given an undertaking to comply with the Code. The ABPI’s privacy notice in relation to Disclosure UK can be found here.

We may also collect further data from you such as your email address or third party ID, in order to share it with the ABPI for purposes other than publication on Disclosure UK, e.g. sending you notifications regarding the disclosure portal or improving the accuracy of data matching.

We also collect your personal data for direct communications from Flynn Pharma Ltd regarding your transfer of value.

The legal basis for processing your personal data

The law requires us to inform you of the legal basis for collecting and processing your personal data where we are the data controller.

Transfers of Value

Where we process data relating to transfers of value made to you, we rely on the following legitimate interests to process that data:

Flynn Pharma Ltd has a legitimate interest in using information about the transfers of value that you received from us so that we can comply with our obligations under the Code.
Furthermore, we recognise there is a legitimate public interest in better understanding the financial relationships that covered individuals may have with the pharmaceutical industry in the interests of transparency and trust in the pharmaceutical industry.

Compliance with the Code and these objectives cannot be achieved without processing personal data about you and the transfers of value that you have received from us. We have carried out a Legitimate Interests Assessment and consider that this processing is necessary, proportionate and without unjustified harm to you.

A separate Legitimate Interest Assessment guidance will be kept in writing in case and can be provided upon request.

How we share your data

We may share your personal data relating to transfers of value with the parties set out below:

The ABPI, for the purpose of complying with the Code. The ABPI will validate and publish your personal data on the Disclosure UK website.
Uniphar Group, for the purpose of providing a system in which we can store our records

Do we transfer your data abroad?

The ToV (Transfer of Value) personal data is not transferred or processed abroad. All data is stored and processed within the United Kingdom. Therefore, no international data transfers take place, and no additional safeguards under the UK GDPR are required.

How do we keep your data secure?

The organisation has implemented a comprehensive framework of organisational and technical controls to ensure the lawful, fair, and secure processing of pharmaceutical disclosure (ToV) personal data in accordance with applicable data protection legislation.

Key measures include:

Policies and Governance: Documented data protection, confidentiality, and information security policies are in place. These are reviewed periodically to ensure ongoing compliance and effectiveness.
Staff Awareness and Training: All relevant personnel receive regular training on data protection principles, confidentiality, and secure handling of personal data.
Access Control: Access to ToV personal data is restricted to authorised staff based on defined roles and responsibilities.
Technical Safeguards: Appropriate security measures are implemented, including encryption of data at rest and in transit, multi-factor authentication, firewalls, and secure, regularly tested backups.
Data Minimisation and Retention: Only data strictly necessary for disclosure and transparency purposes is collected, stored securely, and retained only for the required duration before secure deletion or anonymisation.
Third-Party Management: Where external service providers are engaged, formal data processing agreements ensure that equivalent confidentiality and security standards are applied.
Incident Management: A documented incident response process is in place to identify, investigate, and report any personal data breaches in a timely manner, in line with regulatory requirements.

For how long will your personal data be kept?

Under the Code, companies under law must retain records of all disclosures made to Disclosure UK for at least five years after the end of the calendar year to which they relate. Flynn Pharma Ltd will therefore keep your personal data about transfers of value or benefits in kind for at least five years, to meet its obligations, to ensure that the information published by the ABPI on Disclosure UK is accurate and to resolve any questions or queries relating to the personal data.

Your rights

Under data protection laws, in certain circumstances you have the rights set out below in relation to your personal data. If you wish to make a request to access one of these rights, please contact us:

medinfo@flynnpharma.com
Flynn Pharma Ltd
Hertlands House
Primett Road
Stevenage
SG1 3EE

Object to the Processing of your Personal Information

You have a right to object to the processing of your personal information where that processing is based on our legitimate interests, such as our disclosure of your transfer of value data to the ABPI. If you make an objection request, we shall seek to ensure a balance is struck between your rights and freedoms and our legitimate interests. We will cease processing your data in this way unless we can demonstrate compelling and legitimate grounds for the processing.

How to contact us