PRIVACY POLICY

Privacy & Personal Data Protection Policy
Last updated: 12 March 2026

Data controllerR&D Pharma
Address5, Rue du Gabian, 98000, Monaco
Email
contact@rd-pharma.mc

R&D Pharma is established in the Principality of Monaco and is responsible for the collection and
processing of personal data in connection with its activities, including website interactions,
investigator-initiated research (IIR) submissions, contact requests, newsletter subscriptions, and
related communications.

Applicable legal framework

R&D Pharma processes personal data in accordance with:

  • Monegasque Law No. 1.565 of 3 December 2024 on the Protection of Personal Data (the “Monaco Data Protection Law”), which incorporates principles aligned with the European General Data Protection Regulation (EU 2016/679) (“GDPR”);
  • European General Data Protection Regulation (EU) 2016/679 (“GDPR”), to the extent applicable when processing personal data of individuals within the European Union;
  • Other applicable laws and regulations relating to personal data protection and privacy.

Supervisory Authorities

The authority responsible for data protection supervision and enforcement in Monaco is:
Autorité de Protection des Données Personnelles (APDP).
For data processed in connection with individuals in France or the European Union, the French Data
Protection Authority (CNIL) may also be relevant.

Purposes and legal bases for data processing

R&D Pharma processes personal data only for specific, explicit and legitimate purposes, including:

PurposeLegal Basis
Responding to contact form inquiriesConsent (Article 6(1)(a) GDPR / Monaco law)
Evaluating Investigator-Initiated Research (IIR)
submissions
Legitimate interest / Consent
Sending newsletters and marketing
communications
Consent
Website statistics and analyticsConsent
Compliance with legal and regulatory obligationsLegal compliance

Personal data will be processed only for the purposes stated at the time of collection.

Types of personal data collected

R&D Pharma may collect:

  • Identification data: name, professional contact details
  • Communication data: email, telephone
  • Professional IP data for research proposals
  • Technical data: IP address, device and browser information (via cookies)

Cookies and tracking technologies

We use cookies to:

  • Facilitate essential website functionality
  • Allow analytics that help us improve our web presence

Consent for cookies is obtained via a cookie banner.
No analytics or marketing cookies are placed without prior consent.
Users may change their preferences at any time via the cookie consent banner or browser settings.

Data sharing and recipients

R&D Pharma may share personal data with:

  • Service providers and processors acting on behalf of the company
  • Authorities, where required by law or regulation
  • Scientific partners for legitimate research collaboration (only with explicit consent or
  • contractual basis)

No personal data will be sold to third parties.

International transfers

Personal data may be transferred outside of Monaco or the European Economic Area only where
appropriate safeguards are in place, such as Standard Contractual Clauses, Binding Corporate Rules,
or where transfers are otherwise permitted under applicable law.

Data retention

Personal data is retained only for as long as necessary to achieve the purposes for which it was
collected or to comply with legal requirements.

Processing activityType of dataRetention periodLegal / Operational basis
Contact form inquiriesName, email, message content3 years from last contactLegitimate interest / Pre contractual measures
Investigator-Initiated
Research (IIR)
submissions
Professional data,
proposal content
10 years after study
closure or decision
Regulatory documentation /
Clinical governance
Website analytics dataIP (anonymized), usage data13 months maximumConsent (CNIL/APDP aligned practice)
Cookie consent logsConsent status,
timestamp
6 monthsProof of consent obligation
Pharmacovigilance
reports
Adverse event data
(including personal data where applicable)
10 years after expiry of marketing authorisationEU pharmacovigilance
legislation
Medical Information
requests
Contact details, inquiry content10 yearsRegulatory traceability
Contractual partner
Data (HCPs, CDMOs,
Suppliers)
Professional contact dataDuration of contract + 5 yearsContractual obligation

Data security

Appropriate technical and organisational measures are in place to protect data against unauthorized
access, disclosure, alteration or destruction.

Data subject rights

Individuals have the following rights with respect to their personal data:

  • Right of access: obtain confirmation of whether your data is processed
  • Right to rectification: correct inaccurate or incomplete data
  • Right to erasure: request deletion of data where permitted
  • Right to restriction: limit processing in specific cases
  • Right to object: object to processing on grounds relating to personal situation
  • Right to data portability: receive your data in a structured, commonly used format

Requests may be sent to R&D Pharma’s Data Protection Officer (DPO) at:
dpo@rd-pharma.mc

Right to lodge a complaint

Individuals have the right to lodge a complaint with the relevant supervisory authority:

  • APDP : Autorité de Protection des Données Personnelles (Monaco)
    Website: https://www.apdp.mc
  • CNIL : Commission Nationale de l’Informatique et des Libertés (France)
    Website: https://www.cnil.fr

Updates to this Policy

This policy may be updated periodically. The latest version will always be available on our website
with the effective date clearly stated.