Effective: September 9, 2025
- Purpose of the policy
The purpose of this policy is to set out the principles and rules of personal data processing carried out by SolDRA International Kft. (the “Company”) in accordance with:
- Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR),
- Act CXII of 2011 on the right to self-determination in relation to information and freedom of information (Infotv.),
- Act CLIV of 1997 on healthcare,
- Act XCV of 2005 on medicinal products and the distribution of medicinal products for human use,
- Decree 44/2004. (IV. 28.) ESzCsM on the marketing of medicinal products,
- and the pharmacovigilance guidelines of the European Medicines Agency (EMA) (Good Pharmacovigilance Practice, GVP).
- Data controller details
- Company name: SolDRA International Kft.
- Registered office: [address can be entered]
- Representative: Dr. Gergely Zajzon, managing director
- Contact: [e-mail, telephone number]
The Company has not appointed a separate data protection officer (DPO).
The person responsible for data protection is: Dr. Gergely Zajzon, managing director.
- Legal basis and purposes of data processing
3.1. Readability assessment of patient information leaflets
- Purpose: to assess whether the patient information leaflets for medicines are understandable to participants.
- Legal basis: the voluntary, prior and explicit consent of the data subject (GDPR Article 6(1)(a), Infotv. Section 5(1)(a)).
- Data categories: name, contact details, answers given during the test.
- Retention period: max. 2 years after the examination is completed, then deletion/anonymization.
- Data subject rights: access, rectification, erasure, restriction, objection, withdrawal of consent.
3.2. Pharmacovigilance – collection of adverse reactions
- Purpose: compliance with legal obligations for the sake of drug safety.
- Legal basis: compliance with legal obligations (GDPR Article 6(1)(c)), public interest in the case of special categories of data (GDPR Article 9(2)(i)), based on Section 17 of Act XCV of 2005 and related implementing regulations.
- Data categories: health data of the data subject, details of side effects, contact details.
- Retention period: in accordance with pharmacovigilance legislation, for at least 10 years after the product has been withdrawn from the market.
- Rights of data subjects: may be exercised to a limited extent if the deletion or restriction of data is not possible due to legal obligations.
- Data security
The Company applies technical and organizational measures to protect data in accordance with Article 32 of the GDPR and Section 7 of the Infotv.
- Restricted access
- Password-protected IT systems
- Regular data backup
- Secure storage of paper-based documents
- Data transfer
The Company transfers personal data in the following cases:
- Rights and remedies of data subjects
Data subjects have the right to:
- request information about the processing of their data (Section 14 of the Information Act),
- access their personal data (GDPR Article 15),
- request rectification (GDPR Article 16),
- request erasure or restriction of processing (GDPR Articles 17-18),
- withdraw consent (GDPR Article 7(3)).
In case of complaints, data subjects may contact the National Authority for Data Protection and Freedom of Information (NAIH)
(1055 Budapest, Falk Miksa u. 9–11., www.naih.hu).
- Final provisions
The Company shall review the regulations annually or as necessary.
Date: Budapest, September 9, 2025.
Dr. Gergely Zajzon
Managing Director