Privacy Policy

Eurodrug Laboratories B.V. Data Privacy Statement

(a)the identity of the controller and, where applicable, of the controller’s representative;

(b)the contact details of the controller, where applicable;

(c)the purposes of the processing for which the personal data are intended as well as the legal basis for the processing.

(d)where the processing is based on point (f) of Article 6(1), the legitimate interests pursued by the controller or by a third party

(e)the recipients or categories of recipients of the personal data, if any;

(f) where applicable, the fact that the controller intends to transfer personal data to a third country or international organisation and the existence or absence of an adequacy decision by the Commission, or in the case of transfers referred to in Article 46 or 47, or the second subparagraph of Article 49(1), reference to the appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available.

(g1) the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;

(g2) the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability;

(g3) where the processing is based on point (a) of Article 6(1) or point (a) of Article 9(2), the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;

(g4) the right to lodge a complaint with a supervisory authority;

(g5) whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data;

(g6) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

(a)

Eurodrug Laboratories B.V (and its authorized representatives) is the controller and responsible for your personal data (referred to as “Eurodrug”, “we”, “us” or “our” in this privacy notice).

The following are authorized representatives of Eurodrug for the purposes of this notice:

• Eelco Broersma

• Cosme Martinez

• Emanuele de Libero

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

(b)

Eurodrug Laboratories B.V.

Regulusweg 10, 2516 AC, The Hague, The Netherlands

VAT No.: 006169338

E-Mail: info@eurodrug.nl

Telephone number: +31704167373

1. INTRODUCTION

In accordance with the General Data Protection Regulation ((EU) 2016/679) (“GDPR”), Eurodrug Laboratories B.V. (“Eurodrug”) has the obligation to inform you about the scope of use of your personal information and our policies to keep it secure.

This Privacy Statement sets out the basis on which we gather, use, process and disclose any personal data we collect from you, or that you provide to us. We will use your personal data only for the purposes and in the manner set forth below which describes the steps we take to ensure our processing of your personal data follows the GDPR.

(c )

2. LAWFUL BASIS FOR THE PROCESSING

According to Article 6 GDPR, for us to be able to process your data we must comply with:

(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.

(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.

(b) Legal obligation: the processing is necessary for to comply with the law

(d) Vital interests: the processing is necessary to protect someone’s life.

(e) Public task: the processing is necessary to perform a task in the public interest or for official functions and has a clear basis in law.

(f) Legitimate interests: the processing is necessary to legitimate the company´s or third parties legitimate interests, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.

Therefore, and for your further clarification:

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

3. PURPOSES OF THE PROCESSING FOR WHICH THE PERSONA DATA IS INTENDED

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data when it is:

– Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services)

– Necessary for our legitimate interests (to study how customers use our products and services, to develop them and grow our business)

– Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

– Necessary for our legitimate interests (to study how customers use our products or services, to develop them, to grow our business and to inform our marketing strategy)

– Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

– Necessary for our legitimate interests (to develop our products/services and grow our business)

4. CHANGES OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason being it compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

(d)

5. HOW DO WE USE YOUR PERSONAL DATA?

In the contact form on the Eurodrug website you are asked to fill in the following information: your name, company name and email address. This information is only sent to the specific department concerning your request. There are a limited number of people who are eligible, per department, to receive the requests through the website. All employees who have access to this information need special authentication to enter this information. The information is solely used to follow up the request on the website. After the request has been forwarded to the concerning department, the request is deleted.

Accordingly, we will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

– Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

6. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with External Third Parties in the pursue of our above listed legitimate interests.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

Nonetheless, we require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

(f)

7. INTERNATIONAL TRANSFERS

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

– We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

– Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

(g1-6)

8. HOW LONG WILL WE USE YOUR PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

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.

9. WHICH ARE YOUR RIGHTS AS A DATA SUBJECT?

Whenever we process Personal Data, we take reasonable steps to keep your Personal Data accurate and up to date for the purposes for which they were collected. We will provide you with the ability to exercise the following rights under the conditions and within the limits set forth in the law.:

– Request access to your personal data: Enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

– Request correction of your personal data: enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

– Request erasure of your personal data: enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

-Object to processing of your personal data: you may object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

-Request restriction of processing your personal data: Enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

-Request transfer of your personal data: We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

-Right to withdraw consent: where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

– Right to lodge a complaint with a supervisory authority: If any of your abovementioned data rights have been violated, you can take the following steps for raising a complaint.

• Lodge a complaint with a supervisory authority (Art. 77 GDPR)

• File for an effective judicial remedy against a supervisory authority / a controller or processor (Arts. 78, 79 GDPR)

• Receive compensation and liability (Art. 82 GDPR)

10. WHAT HAPPENS IF YOU FAIL TO PROVIDE YOUR PERSONAL DATA?

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

11. WHICH ARE THE CONSEQUENCES OF AUTOMATED DECISION MAKING (INCLUDING PROFILING) FOR YOU?

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

12. AMENDMENT OF PRIVACY STATEMENT

We may update our Data Privacy Statement from time to time. Updates of our Privacy Statement will be published on our Website. Any amendments become effective upon publication on our Website. We therefore recommend that you regularly visit the site to keep yourself informed on possible updates.

13. CONTACT

For any questions you may have with respect to data privacy, please contact the legal department of Eurodrug at the following address:

legal@eurodrug.nl

Regulusweg 11

2516 AC The Hague

The Netherlands