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Privacy Policy

ASYA MANAGEMENT SAGL (Corso San Gottardo, 85 Chiasso, Switzerland, “Asya”), respects your privacy and is committed to protecting your personal data. This Privacy Policy will tell you about how we look after your personal data when you visit our websites and tell you about your privacy rights and how the law protects you.

This Privacy Policy aims to give you information on how Asya collects and processes your personal data through your use of its websites, including any data you may provide through these sites when you sign up to our newsletters.

This website is not intended for children and we do not knowingly collect data relating to children, unless we have agreed this with you.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

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WHO WE ARE

This Privacy Policy is issued on behalf of Asya so when we mention ”Asya”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the Asya responsible for processing your data.

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THE DATA WE COLLECT ABOUT YOU

Personal data means any data about an individual from which that person can be identified. It does not include data where the identifiers have been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Contact data including billing address, delivery address, email address and telephone numbers;

  • Technical data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;

  • Usage data including information about how you use our website, products and services; and

  • Marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data, such as statistical or demographic data, for any purpose. aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this Privacy Policy.

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WAYS OF OBTAINING PERSONAL DATA

In most cases, Asya will collect data directly from you.

When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary for us to provide the requested services, we may not be able to provide you those services.

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PURPOSES OF PROCESSING PERSONAL DATA

Asya will process your personal data only for purposes permitted by applicable laws, which may vary depending on where you live, and where Asya operates, and on the terms set forth in this Privacy Policy. The purposes of the data processing activities may include:

  • Market access to our consulting services

  • Marketing purposes

  • IT and digital activities;

Asya will process personal data for further purposes, where lawful to do so (such as for archiving or scientific purposes) or when legally obliged to do so.

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LEGAL BASIS OF PROCESSING

Asya processes personal data based on one or more of the following conditions:

  • Where you have provided your consent (in which cases, such consent can be withdrawn at any time and without giving any reason);

  • Where it is necessary to comply with contractual obligations with you;

  • Where the processing is necessary for our compliance with a legal obligation;

  • Where the processing is necessary to protect the vital interests of an individual;

  • Where processing is necessary in the public interest or for a public task; or

For instance, where the processing of data is referred to the provision of market access and specialty distribution services, the performance of a contract constitutes the legal basis for the processing in accordance with Article 6, paragraph 1, letter b) of the GDPR.

Where the processing of data is referred to marketing purposes, consent constitutes the legal basis for the processing in accordance with Article 6, paragraph 1, letter a) of the GDPR.

Respectively, the legal basis of the processing of data for pharmacovigilance purposes is the fulfilment of legal obligations provided by law and by the regulations applicable to pharmacovigilance pursuant to Article 6, paragraph 1, letter c) of the GDPR.

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SPECIAL CATEGORIES OF DATA

In addition to the above, where Asya processes special categories of data about individuals, it shall only do so in accordance with applicable laws and regulations. For such processing Asya relies on the following conditions:

  • Where individuals provide explicit consent;

  • Where required for rights and obligations related to employment;

 

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will not send you unsolicited marketing information without your consent, and we will get your express opt-in consent before we share your personal data with any company outside the Asya of companies for marketing purposes.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via letter, email or text message, or where we are processing your sensitive personal data.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us that we are required to retain as a result of any product/service purchase or other transactions.

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THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

 

HOW SECURE IS MY DATA?

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, applicable data protection laws and regulations as well as international security standards. All data you provide to us is stored on secure servers and accessed and used subject to our security policies and standards. Asya has implemented reasonable physical, technical and managerial controls and safeguards to keep your personal data protected from unauthorised access, disclosure, alteration, and destruction. Such measures may include, but are not limited to: firewalls, access controls, encryption of information while it is in storage, separation of duties, and similar security protocols. Access to your personal data is limited to a restricted number of Asya’s employees whose duties reasonably require such information and third parties with whom Asya contracts to carry out business activities on its behalf. Our employees have been trained on the importance of privacy and how to handle and manage personal information appropriately and securely.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will retain your personal data for the time strictly necessary to achieve the purposes for which the data were collected and any other permitted associated purpose. Data may be retained for a longer duration where applicable laws or regulations require or allow Asya to do so. When your data is no longer needed it will be either irreversibly anonymized (and the anonymized information may be retained) or securely destroyed.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

AUTOMATED DECISION MAKING

Asya does not undertake through its website or in general decisions based solely on automated processing, including profiling, of an individual unless we inform you otherwise.

 

YOUR DATA PROTECTION RIGHTS

Under applicable laws and subject to any legal restrictions, you may have the right to request us to:

  • Provide you with further details on the processing of your personal information;

  • Provide you access to your personal data that we hold about you;

  • Update any inaccuracies in the personal information we hold that is demonstrated to be inaccurate or incomplete;

  • Delete any personal information that we no longer have a lawful basis to use;

  • Provide you or a third party, with a copy of your data in a digital format (data portability);

  • Stop a particular processing when you withdraw your consent;

  • Object to any processing based on the legitimate interests or public interest to process information, unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and

  • Restrict certain aspects of the processing of your information.

You are also entitled to lodge a complaint with the supervisory authority for the protection of personal data of your country of residence or place of work, if you consider that your statutory rights have not been respected or that you have not received a response to your requests according to the specifications of law.

 

POLICY UPDATING

Asya reserves the right to amend this Privacy Policy from time to time to reflect technological advancements, legal and regulatory changes, and Asya’s business practices, subject to applicable laws. If Asya changes its privacy practices, an updated version of this Privacy Policy will reflect those changes by posting any revisions on with the respective update of the effective date listed on the bottom of this Privacy Policy. We therefore encourage you to periodically visit this page to stay informed of how we are using your personal data.

CONTACT INFORMATION

If you have any questions in relation to this Privacy Policy, or you want to obtain more information about Asya’s privacy practices, please contact our office by email at amministrazione@asyam.ch

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Last updated on March,16th 2026

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