Privacy Policy

The controller of your personal data is PUBE GLOBAL Sp. z o.o., a company registered in Poland with the following details:

• Registered office: Poland
• NIP (Tax ID): 5423250847
• REGON: 363197263
• KRS: 0000590495
• Share capital: 1,000,000.00 PLN
• Email: info@pubeglobal.com
• Phone: +48 731 691 389
• Website: https://pubeglobal.com

For any questions relating to the processing of your personal data, please contact us at: info@pubeglobal.com.

This Privacy Policy applies to personal data collected through the PUBE GLOBAL website and any related interactions, including contact forms, email correspondence, medical incident and adverse reaction reporting, and business enquiries.

This website is directed exclusively at business professionals, pharmaceutical companies, healthcare institutions, and other legal entities operating in the pharmaceutical and healthcare sector. We do not knowingly collect personal data from private individuals or consumers.

We process personal data on the following legal grounds under the General Data Protection Regulation (EU) 2016/679 (“GDPR”):

• Article 6(1)(b) — Performance of a contract: processing necessary to fulfil a business enquiry, commercial agreement, or pre-contractual steps taken at your request.
• Article 6(1)(c) — Legal obligation: processing required to comply with applicable EU and Polish law, including pharmacovigilance regulations, import/export documentation requirements, and mandatory incident reporting.
• Article 6(1)(f) — Legitimate interests: processing necessary for our legitimate business interests, such as maintaining business communications, improving our services, and website analytics — provided such interests are not overridden by your rights.
• Article 6(1)(a) — Consent: where you have explicitly agreed to specific processing, such as receiving commercial communications or the use of optional analytics cookies.

4.1 Contact and Business Data

When you contact us or submit a business enquiry, we may collect:

• Full name and job title
• Business email address and telephone number
• Company name and registered address
• Content of your correspondence
• Information about products, markets, or services you enquire about

4.2 Medical Incident and Adverse Reaction Reporting

Where you submit a medical incident or adverse reaction report via our dedicated reporting forms, we may collect:

• Contact details of the reporting professional
• Patient information (where required by law — reported data is handled strictly in accordance with applicable pharmacovigilance regulations under Regulation (EC) No 726/2004 and Directive 2001/83/EC)
• Details of the incident or adverse reaction

Data collected for pharmacovigilance purposes may be subject to mandatory reporting obligations to relevant national and EU competent authorities.

4.3 Website Usage Data (Analytics Cookies)

With your consent, we collect anonymised data about how the website is used (e.g., pages visited, time on site) through analytics cookies. This data does not identify you personally. See Section 9 for full cookie details.

We use collected data for the following purposes:

• Responding to business enquiries and managing commercial relationships
• Providing regulatory, sourcing, logistics, and licensing services
• Processing and forwarding mandatory medical incident and adverse reaction reports to competent authorities
• Sending service-related communications (non-marketing)
• Improving the functionality and content of our website
• Complying with legal and regulatory obligations under EU and Polish law

6.1 Third Parties

We do not sell or rent your personal data. We may share data with trusted third parties only where necessary:

• IT and hosting service providers (website hosting, email services)
• Analytics service providers (under data processing agreements)
• Legal, financial, or regulatory advisors
• Competent authorities where required by law (e.g., Chief Pharmaceutical Inspectorate, EMA, national health authorities)

6.2 International Transfers

If personal data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place in accordance with Chapter V of the GDPR, such as Standard Contractual Clauses (SCCs) approved by the European Commission or adequacy decisions.

We retain personal data only for as long as necessary for the purposes described in this Policy, or as required by applicable law:

• Business correspondence and contract-related data: 5 years from the end of the business relationship, in accordance with Polish commercial and tax law.
• Pharmacovigilance and incident reports: as required by applicable EU pharmacovigilance regulations, typically a minimum of 10 years.
• Analytics data: up to 26 months from collection, or in line with the analytics provider’s data retention policy.
• Consent records: for the duration of the consent and until any statutory limitation period expires.

As a data subject under GDPR, you have the following rights:

• Right of access (Article 15): to request a copy of the personal data we hold about you.
• Right to rectification (Article 16): to request correction of inaccurate or incomplete data.
• Right to erasure (Article 17): to request deletion of your data where there is no compelling reason for its continued processing.
• Right to restriction (Article 18): to request that we limit the processing of your data.
• Right to data portability (Article 20): to receive your data in a structured, machine-readable format.
• Right to object (Article 21): to object to processing based on legitimate interests.
• Right to withdraw consent (Article 7(3)): to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at: info@pubeglobal.com.

You also have the right to lodge a complaint with the competent supervisory authority. In Poland, this is the President of the Personal Data Protection Office (UODO): https://uodo.gov.pl.

Our website uses cookies. We use two categories of cookies:

• Essential cookies: Required for the website to function correctly. These cannot be disabled.
• Analytics cookies: Used to understand how visitors interact with the website, enabling us to improve its content and usability. These are only set with your explicit consent.

You can manage your cookie preferences at any time via the cookie consent banner on the website. Withdrawing consent will not affect any processing that took place prior to withdrawal.

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or disclosure, in accordance with Article 32 of the GDPR. These measures are reviewed and updated regularly.

We may update this Privacy Policy from time to time. The most current version will always be available on our website. We will notify users of material changes where required by law.

For any questions, requests, or concerns regarding this Privacy Policy or the processing of your personal data, please contact: