1. Introduction

Axium Buying Group, trading as Thera Pharmaceuticals Ltd (Registered IE460397) at the address Unit 1, Trinity Court, Fonthill Retail Park, Dublin 22, respects your right to privacy and complies with our obligations under the EU General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018.

The purpose of this website Privacy Statement is to outline how we deal with any personal data you provide to us while visiting this website. Any external links to other website are clearly identifiable as such, and we are not responsible for the content or the privacy policies of these other websites.

2. Types of Information Collected

We collect and process two types of information via our website:

Personal Data: This is data that identifies you or can be used to identify or contact you and may include your name, address, email address, supplier account numbers, user IP addresses in circumstances where they have not been deleted, clipped or anonymised, telephone number, and billing information. Such information is only collected from you if you voluntarily submit it to us.

Non-Personal Data: Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our web site. This non-personal data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses where they have been clipped or anonymised, browser types and other anonymous statistical data involving the use of our website.

Cookies: This website uses “cookie” technology. For details of our Cookies Policy, click the Cookie Policy link at the bottom of this page.

3. Purposes for which we hold your Information

Non-Personal Data: We use the non-personal data gathered from visitors to our website in an aggregate form to get a better understanding of where our visitors come from and to help us better design and organise our website.

Personal Data: We will process any personal data you provide to us for the following purposes:

• if you are a member of the Axium Buying Group, to process your orders for products available for purchase on this website – e.g. using account information provided;
• to contact you if required in connection with your orders and order history or to respond to any communications you might send to us; and
• to communicate with you about Axium Buying Group activities, including sending you promotional and marketing materials, subject to any preferences that you may express when we collect your contact details or subsequently.  You can opt out of receiving promotional and marketing materials from us at any time by contacting customerservice@axium.ie.

4. Legal bases for processing personal data

The legal bases on which we process your personal data are that:

• this is necessary for compliance with a legal or regulatory obligation that applies to us;
• this is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract with you;
• this is necessary for the purposes of our legitimate interests in dealing with users and members, including but not limited to in respect of marketing and promoting our products and services and conducting our business in a responsible and commercially prudent manner. We will not process your personal data for these purposes if such legitimate interests should be overridden by your own interests, rights and freedoms; or
• in limited circumstances, where you have given your consent to our processing of your personal data. 

5. Disclosure of Information to Third Parties

We may provide non-personal data to third parties, where such information is combined with similar information of other users of our website. For example, we might inform third parties regarding the number of unique users who visit our website, the demographic breakdown of our community users of our website, or the activities that visitors to our website engage in while on our website. The third parties to whom we may provide this information may include potential or actual suppliers, providers of advertising services (including website tracking services), commercial partners, sponsors, licensees, researchers and other similar parties.

We may disclose your personal data to third parties in connection with the above purposes, including to third parties who we engage to provide services to us in connection with this website, such as outsource service providers, IT service providers, professional advisers and auditors.

We may disclose your personal data to competent regulatory authorities and bodies as requested or required by law, e.g. under, a summons, a search warrant, a court or regulatory order, or other statutory requirement.

We may disclose your personal information to third parties, their agents and professional advisors, subject to confidentiality obligations, for the purpose of a due diligence exercise by third parties in connection with any proposed merger, acquisition, re-organisation or transfer of any part of our business and to any person proposing to participate in, or promote or underwrite or manage any such arrangement.

6. Security

Your personal data is held on secure servers hosted by Hertzner Online GmbH. The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect your personal data.

7. Retention

We will not hold your personal data for longer than is necessary. We retain your personal data for as long as we need it for the purposes described in this Privacy Statement, or to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise between you and us.

8. Requirement to provide personal data

You are not under a statutory or contractual obligation to provide us with any personal data, except where you must provide us with contact details to allow us to contact you with regard to orders submitted through Axium as a member of the Axium Buying Group. If you do not provide us with the information required, we may not be able to process your application form.

9. Transfers Abroad

In connection with the above we might transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers.  These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission or, in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework. If you would like to receive further details of the measures that we have taken in this regard, please contact us at info@axium.ie.

10. Your rights

You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your personal data:

• Right to access the data – You have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.
• Right to rectification – You have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete.
• Right to erasure – You have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten.
• Right to restriction of processing or to object to processing – You have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.
• Right to data portability – You have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine readable format.

11. Changes to the Privacy Statement

Any changes to this Privacy Statement will be posted on this website so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it..

12. Questions or Comments

If you wish to contact us to discuss any matter in relation to this Privacy Statement or our processing of your personal data, please feel free to contact us by email at info@axium.ie.

You also have the right to lodge a complaint with the Irish Data Protection Commission if you are not happy with the way we have used your information or addressed your rights.  Details of how to lodge a complaint can be found at (https://www.dataprotection.ie/docs/Contact-us/11.htm) or you can call the Data Protection Commission at 353 (0)761 104 800.