Effective as of May 24, 2018

This Privacy Policy outlines the terms and conditions under which Cromos Pharma LTD, a legal entity registered and operating at Suite 40, the Guinness Enterprise Centre, Taylors Lane, Dublin 8, Ireland, and its affiliates worldwide (“Cromos Pharma”) processes personal data.

We are committed to ensure that your privacy is protected and personal data is processed in full compliance with applicable legislation.

Cromos Pharma may act as the controller for the processing of personal data for the purposes described herein, as well as be engaged as data processor by its counterparties based on the agreements made with them. For any matters connected with this Privacy Policy, please contact us at the following address: privacy@cromospharma.com.  

Types of collected information

We may collect the following information about you:

• name and family name, job title and information concerning your organization;

• contact details, including phone number, e-mail address, social media/messaging service (Skype, WhatsApp, etc.) accounts and numbers;

• cookies, information concerning your usage of our website www.cromospharma.com (“Web Site”), and other information related to customer surveys, or

• information regarding your age, residential address, passport/ID details, job experience, education, marital status, business correspondence with us, bank accounts and other information provided by you within employment application process, and/or for purposes of contract execution.  

Purposes of Data Processing

Based on our legitimate interest, and unless you have specifically limited usage of your personal data when providing it to Cromos Pharma, we will use your personal data in the scope not exceeding reasonably necessary for a particular purpose, as follows:

• to support internal record keeping of our clients, vendors, employees and service providers to execute and perform contract consummated with you, as well as to promote our services and products to optimize our business processes;

• to support our potential and current client database for providing you with targeted services and products, receiving feedback on your interest in our services and products;

• to support our potential and current vendor database for requesting services and products from you;

• to provide your data to state authorities in cases specifically introduced by applicable legislation based on executed contract (employment, tax, and other mandatory rules);

• in case of your specific consent thereto, to send promotional emails, presentations, service proposals, special offers, newsletters, business initiatives, and other information we think you may find interesting using provided contact details;

• to evaluate your personal information and propose collaboration (employment, engagement, etc.) using provided contact details and related personal data, and

•to customize our website and services according to your interests

No automated decision making (profiling, etc.) is being carried out by Cromos Pharma. We shall not use any source of the personal data other than information provided by the data subject directly, or made available to the public in a legal manner.  

Categories of Recipients of the Personal Data

Your personal data may be transferred for processing to the following third parties:

• Cromos Pharma group of companies and affiliates, as well as partner firms engaged in joint or partnership activities with Cromos Pharma (in the scope not exceeding what is required for your engagement with such third parties);

• Cromos Pharma accounting, HR, legal, IT, data centers and other service providers acting on the basis of the agreement, and

• Cromos Pharma customers, agents, contractors and other counterparties solely for the purposes of due fulfillment of our contract with you, and under terms and condition thereof.

Your personal data may be transferred to third parties outside the USA and the European Union on condition Cromos Pharma adopts all necessary safeguards to ensure safety of personal data (including usage of Standard Contractual Clauses as set forth by the EU Commission, implementation of technical and organizational security measures, and other reasonable measures). Upon your request the information on safeguards adopted for transfer of your personal data can be provided.  

Data Subject Rights

You have the following rights regarding your personal data:

• right of access which means the right to know whether data concerning you is being processed and to access it;

• right to rectification by means of providing a supplementary statement about missing, incomplete or incorrect information;

• right to erasure or right to be forgotten if the personal data has been made public;

• right to require restriction of processing in cases provided by law;

• right to be informed;

• right to data portability;

• right to reject personal data processing;

• right to withdraw consent for personal data processing, and

• other rights provided by applicable legislation.

To exercise your rights please contact: privacy@cromospharma.com.  

Personal Data Retention Period 

Your personal data will be retained for 5 years after the last contact, unless otherwise provided by the applicable legislation, or unless we have received your request for erasure of your personal data or restrictions of processing thereof in accordance with the applicable legislation.  


We do not collect any contact information and we will never send you any direct communication.

You have the right to view, amend, or delete the personal information that we hold about you. To request access please contact privacy@cromospharma.com. We will provide the information free of charge and within one month, except in the event that the request is unfounded, excessive or repetitive, in which case we reserve the right to charge a proportionate administration fee or refuse.  

Rectification of personal information

If any of the information we hold is inaccurate or incomplete, you may ask us to correct or complement it at any time.  

Your right of erasure, or to be forgotten 

You may request the deletion of any of your emails that are in our possessionat any time.

Be aware that requesting deletion, unlike unsubscribing from specific emails, is total and irreversible. This means that we will also lose record of you having ever been on our systems, including any previous instructions you have given us opting out of specific emails types. If you re-join our systems, by voluntarily providing your personal information, you will be viewed by us as a completely new data subject. This does not affect your other rights in any way.

To request deletion of your personal information please contact: privacy@cromospharma.com using the email address we have on file or otherwise proving your identity.  

Cookies Policy 

This website uses cookies. A cookie is a small amount of data generated by a website and saved by your web browser. Its purpose is to remember information about you, similar to a preference file created by a software application. Cookies perform a number of different functions. Some cookies are needed to deliver our website and services to you. Cookies can be "persistent", remaining on your device after you have left the website or can be "session" cookies that are deleted when you close your internet browser. You can use your browser settings to manage your cookie preferences but please note that in doing so, some functionality of the website might not work as effectively.

Links to Other Web Sites 

This Privacy Policy does not cover the links within our website linking to other websites. Those sites are not governed by this Privacy Policy, and if you have questions about how a site uses your information, you will need to reviewthat site’s privacy statement.


We take precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific task (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.  

Changes to this Privacy Policy 

Cromos Pharma may change this Policy from time to time by updating this page. This policy is effective as of 24th May 2018.