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The Court of Justice of the European Union (“CJEU”) has recently issued a significant judgment in the case “Lindenapotheke” (C-21/23), taking a clear stance on the processing of special categories of personal data, namely health data, in the context of online medicine sales within the pharmaceutical industry. The ruling sheds light on how the General Data Protection Regulation (“GDPR”) applies to the data that users provide when ordering pharmacy-only medicinal products online, even those not subject to prescription, and provides clear guidance on the rights and obligations of data controllers.

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