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This page describes the procedures for managing the www.dompe.com site in relation to the processing of personal data of the users who consult it, or who register with it (“the Portal” or “site”).

This information is also provided pursuant to Art. 13 of Legislative Decree of 30 June 2003 No. 196 “Personal data protection code” for those who interact with the web services provided through the aforementioned Portal.

“Processing” of personal data must be understood as the various processing operations of personal data, such as the collection, processing, comparison, cancellation, modification, communication or disclosure of the aforementioned data.

The information is also based on Recommendation No. 2/2001 that the European authorities for the protection of personal data, gathered in the Group established by Art. 29 of Directive No. 95/46/EC, adopted on 17 May 2001 to identify some minimum requirements for collecting personal data online and, in particular, the manner, timing and nature of the information that data controllers must provide to users when they link to web pages, regardless of the purposes of the connection.

The information is provided only for the Dompé site and not for other websites that may be consulted by the user through links.

No data deriving from the web service may be communicated or disseminated, except in cases expressly provided for by law.

The personal data provided by the users are only used to perform the service or provision requested and are only disclosed to third parties if necessary for said purpose.

Data Controller and Data Protection Officer

The data controller is Dompé farmaceutici S.p.A. (“Dompé”), established in Milano in Via San Martino 12-12a, 20122. Dompé has appointed several data processors for different types of processing and subdivided by company functions. The various data processors are domiciled for their functions at the company itself. To find out the names of the various data processors you can write an e-mail to the following address: privacy@dompe.com

Type of data processed

Browsing data
The computer systems and software procedures used to operate this site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This is information that is not collected to be associated with identified interested parties, but which, by their very nature, could, through processing and associations with data held by third parties, allow users to be identified.

This category of data includes the IP addresses or domain names of the computers utilized by the users who connect to the site, the URI (Uniform Resource Identifier) addresses, the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the response from the server (successful, error, etc.), and other parameters relating to the operating system and the user’s IT environment.

This data is used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check the proper functioning and is maintained for the minimum period required by current legislation.

This data could be used to establish liability in hypothetical computer crimes against the site.

Data provided voluntarily by the user
The optional, explicit and voluntary act of sending electronic mail to the addresses indicated in this site entails the subsequent acquisition of the sender’s address, necessary in order to reply to the requests, as well as of any other personal data entered. The processing of sensitive and legal data is excluded and if provided by the User will be cancelled. Specific summary information dedicated to particular services on request will be provided or displayed on the website pages.

Cookies are small text files stored on the user’s computer from the sites that the user visits. They are used in order to make the websites work and operate more efficiently, and to provide information to the owners of the site.

The site uses technical cookies, Google Analytics cookies and third-party cookies.

Technical cookies
These will be installed directly by the Data Controller. They can be divided into browser or session cookies and ensure the normal browsing and use of the website (allowing, for example, to define a browsing session, choose the site language or the font size).

Google Analytics Cookies
Usage of the IP address of the visitor by Google Analytics Cookies

Each computer and device connected to the Internet is assigned a unique number as an Internet protocol (IP) address. Since these numbers are usually assigned to countries in blocks, an IP address can often be used to identify the country, the province and the city from which a computer connects to the Internet. Google Analytics collects the IP address of the website visitors to provide an indication of their geographic location. This method is known as IP geolocation. Google Analytics does not report information related to the actual IP addresses of the visitors. Due to the use of a method known as IP masking, Google Analytics communicates information so that only a part of the IP address is used for geolocation, instead of the whole address. Google may disclose information to third parties where required by law or where such third parties process the information on Google’s behalf.

Browser add-on for deactivating Google Analytics Cookies

A browser add-on can be downloaded to disable Google Analytics. The add-on communicates to the JavaScript code from Google Analytics (ga.js) to indicate that the information about the website visit should not be sent to Google Analytics. The browser add-on for deactivating Google Analytics does not prevent information from being sent to the website itself. In addition, most browsers allow some control of most cookies through the settings of the browser itself. If the user does not wish to receive any type of cookies on his or her computer, the level of privacy protection of the browser can be elevated through the appropriate function. However, some areas of the Portal may not function properly if cookies are refused.

Third party cookies
This is about cookies installed through the site by third parties. With regard to these cookies, the owner and editor of the site is just a technical intermediary and cannot define the procedures and purposes of the operation of said cookies. For information on third-party cookies in use, the reference is to what is shown on the sites of third-party suppliers, in particular: www.doccheck.com and www.addthis.com.

Summary table of cookies required for technical purposes

HP3_USER 60 minutes The purpose of this cookie is to preserve certain data regarding the users connected and their navigation session
ASP.NET_SessionID At the end of the session Cookie session used to maintain anonymous navigation
cookie-compliance-user-response At the end of the session Memorize your choice about the use of optional cookies. Memorize your choice whether to accept or decline the use of optional cookies. No personal data is collected through this Cookie.

Accepting or not accepting cookies can be decided by modifying the browser security settings.

Optionality of Data Transmission

Apart from what has been specified for the browsing data and the use of cookies, the user is free to provide further information or may choose to remain anonymous. In the absence of such data, however, Dompé may not be able to activate any services requested by the user.

Methods of Data Processing

Personal data are processed through automated systems for the time that is strictly necessary to attain the purposes for which they have been collected and in order to fulfil any legal obligations. The data collected through the Portal can be processed by the staff - even occasionally - appointed by Dompé for the processing and/or by consulting companies to whom Dompé could entrust some services.

The personal data of third parties conferred through the registration procedure present in some areas of the Portal will be processed by Dompé for the exclusive purpose of perfecting the user’s registration and activating the services that the user requires. Personal and/or identification data necessary for accessing the Portal and its services are limited to the minimum necessary to be able to reach the user by e-mail and/or to carry out the services that the user requires.

The personal data provided by users through requests for information material (brochures, information material, etc.) are used for the sole purpose of perfecting the service requested and are communicated to third parties only if necessary for said purpose (companies that provide enveloping, labelling, shipping services).

Moreover, in case you want to use the communications services, such as the e-newsletter, for example, you will have the right to cancel your registration at any time by following the instructions given in each individual communication. If you decide to cancel your subscription to a service or communication, Dompé will immediately delete your data.

Sharing, Communication and Disclosure of Data

The Data Controller may be required to communicate data referred to in this information in case the Police Forces collect information by carrying out legitimate investigation and/or judicial police activities (on their own initiative in the case of preliminary investigations or under the direction of the Public Prosecutor). Apart from these cases and the hypotheses expressly governed by the individual information present on the various pages of the site, the data will not be disclosed or transferred to any party.

Dompé reserves the right to communicate the personal data of users to other companies belonging to the group headed by Dompé farmaceutici S.p.A. (the holding company of the Dompé Group) both in Italy and abroad, without prejudice to compliance with this privacy policy. No data deriving from the web service will be disclosed.


Dompé ensures the application of appropriate security measures to prevent access by unauthorized parties, loss, dissemination or improper use of the same, as required by the Privacy Code.

It is the responsibility of the users, however, to ensure that their computer is properly secured and protected from harmful software such as viruses, worms and “Trojan horses”: in fact, without adequate security measures (for example, a secure configuration of the web browser, updated antivirus, software firewall, the use of software of doubtful origin), there is a risk that the data and passwords used to prevent access to their own data are disclosed to unauthorized third parties.

Disclosure and Transfer of Data Abroad

The data collected through the Portal could be transferred to other countries, even outside the European Union, to companies belonging to the Dompé Group. In these cases, we will proceed to their transfer only in the presence of one of the conditions of legitimacy referred to in Article 44 of D.lgs. (Decreto Legislativo [Legislative Decree]) 196/2003 and in Articles 44 and following of the General Data Protection Regulation (EU regulation 2016/679) or, in their absence, in the case of consent given by the interested party.

The personal data of users may be disclosed to third parties in the following cases:

  • sale, cession or other type of transfer of the activity of the site to which the data are linked;
  • when required by laws, government regulations, or court orders or to respond to a specific request from a public authority;
  • when they are necessary for company audits, to examine or respond to a complaint or to a threat to security.

Rights of data subjects

The subjects whom personal data refer to have the right to obtain at any time confirmation as to whether or not personal data relating to them are being processed and to obtain access to such data and know their content and origin, verify the accuracy of the same or request their updating, integration or correction (Article 7 of D.lgs. No. 196/2003 and Articles 15 and subsequent of EU Regulation 679/2016).

The interested party has the right to request the limitation of the processing, portability, cancellation, transformation into anonymous form or the blocking of data processed in breach of the law and to oppose in any case to the processing of such data, for legitimate reasons.

Requests should be addressed by writing an email to privacy@dompe.com

Graphometric Signature

In 2016 Dompé introduced an innovative IT solution to allow the company and the subjects (including customers and suppliers) that enter into contractual relations with it to electronically subscribe accounting and contractual documentation.

A solution in line with the company’s commitment to the dematerialization of accounting and management processes and the gradual replacement of paper documentation with digital documentation.

The graphometric signature service uses a technology that allows to subscribe the documentation directly through a tablet with a particular type of electronic signature that is obtained by recording the dynamic characteristics (rhythm, pressure, coordinates, etc.) of the signature that the subject affixes with his or her own hand on the digital tablet.

For more information on the graphometric signature service and the features of this solution, please consult the attached documents.


Requests relating to the exercise of data subjects’ rights can be addressed to the Data Protection Officer (DPO) by writing an e-mail to DPO@dompe.com


This section of the notice applies solely to visitors, users, health care providers, patients, and others who reside in the State of California (referred to herein as a “consumer” or “consumers”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice. The term “personal data” means “personal information” for purposes of the CCPA.

Personal Data We Collect Under the CCPA

We collect personal data that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. We have collected the following categories of personal data from consumers within the last twelve (12) months:

  • Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers.
    • Protected Classification Characteristics Under California or Federal Law
      • Age (40 years or older), race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex genetic information (including familial genetic information).
  • Commercial Information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Biometric Info. An individual’s physiological, biological, or behavioral characteristics, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, and gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
  • Internet or Other Electronic Network Activity Information. Browsing history, search history, and information regarding a consumer's interaction with a website, application, or advertisement.
  • Geolocation. Physical location or movements.
  • Inferences Drawn from Other Personal Data. Inferences drawn from the information identified above to create a profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Personal data does not include:

  • Publicly available information from government records;
  • De-identified or aggregated consumer information; or
  • Information excluded from the CCPA.

We obtain the categories of personal data listed above from the following categories of sources:

  • You and your devices;
  • Your business partners and employees;
  • Our business partners or their agents;
  • Our website, applications, devices and services;
  • Consumer data resellers;
  • Public records;
  • From third-parties that interact with us in connection with our products and services.

Use of Personal Data

We may use or disclose the personal data we collect for one or more of the following business purposes:

  • Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
  • Performing services, including maintaining or servicing accounts, providing customer products or services, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider;
  • Undertaking internal research for technological development and demonstration;
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us;
  • For business related activities such as contact options, planning, and marketing preferences;
  • As described to you when your personal data is collected, as directed by you or as otherwise permitted under the CCPA or applicable law;
  • When you have provided your consent/authorization, to support benefit resolution and prescription fulfillment; and/or
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us is among the assets transferred.

Sharing Personal Data

We have not sold consumers’ personal data in the preceding 12 months. We may disclose your personal data to a third party for a business purpose. When we disclose personal data for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal data confidential and not use it for any purpose except performing the contract. In the past 12 months, Dompé may have disclosed the following categories of information about consumers for a business purpose:

  • Name and Other Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
    • Protected Classification Characteristics Under California or Federal Law
      • Age (40 years or older), race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex genetic information (including familial genetic information).
  • Commercial Information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Network Activity Information including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
  • Geolocation Data. Business or personal location for delivery of products or services
  • Professional, Education, and Employment-Related Information.
  • Inferences Drawn from any of the information above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We disclose your personal data for a business purpose to the following categories of third parties:

  • Our affiliates;
  • Advertising networks;
  • Internet service providers;
  • Data analytics providers;
  • Government entities;
  • Social networks;
  • Service providers such as entities who provide: IT and related services; services performed on their operating systems and platforms; information you have requested; customer service activities; and our products and services; and/or
  • Third parties to whom you or your agents authorize us to disclose your personal data in connection with products or services we provide to you.

Your Rights and Choices

In accordance with applicable law, you may have the right to:

    Access to/portability of personal data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic personal data transferred to another party.

    Request correction of your personal data where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal data or we may refer you to the controller of your personal data who is able to make the correction.

    Request Deletion of your personal data, subject to certain exceptions prescribed by law.

    If you would like to exercise any of these rights, please log into your account, writing to us or emailing us at privacy@dompe.com or calling +39 02 583831. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.




Requests relating to the exercise of data subjects’ rights can be addressed to the Data Protection Officer, Amalia Crescenzio, by writing an e-mail to