Privacy Policy (Consumers)

Last update: August 2026

Dear Consumer,

With this privacy policy we would like to inform you about

• what personal data we process,
• what we use these data for,
• how you can object to its use or withdraw your consent, and
• what other rights you have as a data subject and how you can assert them.

1. Who is responsible for data processing and whom can I contact?

The responsible body for data processing (data controller) in the sense given in the GDPR is:

Bionorica SE
Kerschensteinerstr. 11–15
92318 Neumarkt
Telephone: +49 (0) 9181 231-90
Fax: +49 (0) 9181 231-265

Our company data protection officer can be reached via email at datenschutz@bionorica.de (mailto:datenschutz@bionorica.de) or by post at the above address (please include the line ‘ATTENTION: Company Data Protection Officer’.

As parent company of the Bionorica group, we provide different services for our subsidiaries pursuant to a consistent corporate management structure (e.g. cross-company IT, communication and database systems, central HR or financial accounting services as well as similar activities at our headquarters in Neumarkt) and also process personal data in this context

In terms of data protection law, this processing is carried out under the joint responsibility of Bionorica SE and the respective subsidiary in accordance with Art. 26 GDPR. The following key points apply to joint processing:

• Bionorica SE and the respective subsidiary are equally responsible for the legality of the joint processing and take appropriate technical and organizational measures so that the rights of the data subjects are guaranteed at all times.
• Bionorica SE undertakes to publish the information required by Art. 13 and 14 GDPR, including in regard to joint processing.
• In order to ensure adequate transparency and reliable assertion of data subject rights, all data subject rights during joint processing can always be asserted against Bionorica SE as the parent company.
• Bionorica SE and the respective subsidiary are equally responsible for the information obligations resulting from Art. 33, 34 GDPR towards the supervisory authority or data subjects affected by a violation of the protection of personal data.
• Both parties are jointly liable for the damage caused by processing that does not comply with the GDPR in the external relationship together towards the data subject.

We would be happy to provide you with an extract from our "Agreement on the joint processing of personal data in accordance with Art. 26 GDPR", as well as an overview of the processing operations for which the subsidiary is solely responsible and those for which we are jointly responsible. For this purpose, please contact the above-mentioned contact.

2. Am I obligated to provide data?

As a consumer, you are generally not obligated to provide us with personal data.

Please note, however, that we can only provide certain offers or services if the required data are made available. This may, for example, be the case when using our online services. Further information can be found in the respective privacy policy on our websites.

3. Which sources and data does Bionorica SE use?

We only process personal data which we receive directly from you (e.g. when you subscribe to newsletters).

An exception may apply in connection with adverse drug reaction reports where we do not receive the information directly from you, but from healthcare professionals (e.g. physicians or pharmacists), provided that you have disclosed the relevant personal data to them and agreed to its transmission to us.

The personal data we process includes, in particular:

• personal details (name, address and other contact data),
• pharmacovigilance data (e.g. health data and information on adverse drug reactions),
• as well as other data comparable to the categories mentioned above.

4. Processing purposes and legal basis

We process personal data in accordance with the provisions of the European General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG) according to the following legal bases.

4.1. To fulfil contractual obligations (Art. 6 para. 1 cl. 1 lit. b GDPR)

Data are processed for performance of contracts concluded with you (e.g. participation in prize draws) and for implementation of pre-contractual measures at your request.

4.2. Based on legitimate interests (Art. 6 para. 1 cl. 1 lit. f GDPR)

In addition, we process personal data to safeguard our legitimate interests in ensuring the proper organisational and operational structure required for managing a pharmaceutical company. This may include, in particular, the following legitimate interests:

• assertion of legal rights and defending ourselves in legal disputes,
• ensuring the IT security and safeguarding of IT operations of our company.

Whilst doing so, we always assess on a case-by-case basis whether our interests in processing outweigh the interests of a data subject in non-processing.

4.3. Based on your consent (Art. 6 para. 1 cl. 1 lit. a GDPR)

If you have granted us or a healthcare professional consent to process personal data for specific purposes (e.g. in connection with the reporting of adverse drug reactions or subscription to newsletters), this processing is lawful based on this consent.

After granting your consent, you can withdraw it at any time. This also applies to the withdrawal of declarations of consent given to us before the GDPR came into effect. Please note that withdrawal of your consent does not affect the lawfulness of processing carried out up to the time of withdrawal.

You can withdraw consent free of charge by sending a formless statement to the contact given in Section 1. If you withdraw your consent by telephone, we may ask you to provide additional proof of your identity in another way.

4.4. To comply with legal obligations (Art. 6 para. 1 cl. 1 lit. c GDPR) or in the public interest (Art. 6 para. 1 cl. 1 lit. e GDPR)

Like every company, Bionorica SE has numerous legal obligations which make processing of personal data necessary. As examples, compliance with tax obligations and regulatory documentation requirements relating to medicinal products can be stated here.

Furthermore, in a few exceptional cases, processing may be necessary in regard to public interest (e.g. the transmission of pseudonymised adverse drug reactions (e.g. side effects) and potential quality defects to the relevant authorities).

5. When is automated individual decision-making used?

We do not use automated decision-making processes.

6. Who gets my data?

Within Bionorica SE, access to your data is granted to those positions and departments that require it for the fulfilment of the tasks covered by your consent.

Carefully selected and controlled service providers engaged by us may also be granted access to data. Such service providers are obligated within the framework of commissioned processing to comply with the data protection requirements that also apply to us. These may include, for example, companies in the fields of IT services or telecommunications.

Data will only be disclosed to recipients outside Bionorica if we have a legal basis for doing so (e.g. legal obligation).

7. Are data transferred to companies in third countries or to international organisations?

Data are only transferred to locations in countries outside the European Union (so-called third countries) if, in addition to general requirements for data transfer, there is also an adequacy decision (Art. 45 GDPR) or appropriate safeguards (Art. 46 GDPR) and, if necessary, additional measures are taken or the requirements of Art. 49 are fulfilled (for example, the corresponding consent).

8. How long are my data stored?

We process your personal data only as long as necessary for fulfilment of our processing purposes described above. Once the data are no longer needed for these purposes, they are erased unless further temporary processing is necessary for the following purposes:

• fulfilment of legal retention obligations. In particular, Commission Implementing Regulation (EU) No. 520/2012 must be mentioned. The retention and documentation period specified therein is at least ten years after the end of the marketing authorisation of the affected product.
• preservation of evidence in the context of the statute of limitations. Pursuant to Sections 195ff. of the German Civil Code (BGB), these statutory limitation periods can be up to 30 years, whereby the normal limitation period is three years.

9. What rights do I have as a data subject?

As a data subject you have the right to access pursuant to Art. 15 GDPR, the right to rectification pursuant to Art. 16 GDPR, the right to erasure pursuant to Art. 17 GDPR, the right to restriction of processing pursuant to Art. 18 GDPR, and the right to data portability according to Art. 20 GDPR. With respect to the right to access and the right to erasure, the limitations set forth in Sections 34 and 35 BDSG apply. You also have the right to lodge a complaint with a responsible data protection supervisory authority (Art. 77 GDPR in conjunction with Section 19 BDSG).

Furthermore, you have the right to object under Art. 21 GDPR. You can object to the processing of personal data on the basis of Art. 6 para. 1 lit. e or f GDPR at any time without giving reasons.