Dear Sir / Madam,
In accordance with art. 13 of Regulation (EU) 2016/679 (General Data Protection Regulation, hereinafter “GDPR”), RECORDATI S.p.A. (“RECORDATI”)/INNOVA PHARMA S.p.A. (“INNOVA PHARMA”) / ITALCHIMICI S.p.A. (ITALCHIMICI) / Natural Point S.p.A. (“NATURAL POINT”) hereby informs you about its processing of the personal data, provided by yourself, to be done in full compliance with applicable laws and regulations and only for the purposes described below.

1. Object of the processing
   
   1. The personal data (your name, address, telephone number, e-mail address) and such further, sensitive data (indicating health status) as you will give us via e-mail or telephone.
2. Purposes and methods of processing
   
   1. The processing of personal data concerning yourself shall be governed by principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy and storage limitation, by ensuring integrity and confidentiality of your data.
   2. The processing will be carried out both by means of computer and on paper; your data are subject to collection and storage both in computer databases and in paper files.
   3. The processing of the data provided by you is done solely in order to respond:
      
      • to spontaneous reports of suspected adverse reactions to medication and to related requests for in-depth study from the personnel of the Pharmacovigilance Department , in compliance with Italian law;
      • to any queries or requests for further study and information relating to RECORDATI/INNOVA PHARMA/ITALCHIMICI / NATURAL POINT products;

      which may be sent to RECORDATI/INNOVA PHARMA/ITALCHIMICI / NATURAL POINT.

   4. The processing shall be carried out in abidance with appropriate technical and organisational measures to ensure a level of security appropriate to the risk of the processing activity, pursuant to article 32 of GDPR and in accordance with the instructions issued by the Data Controller.
   5. Your personal data may be processed (through the operations stated in Article 4, clause 2 of GDPR) i) by the Data Controller, ii) by the Heads of and persons in charge at the Pharmacovigilance Department, by the Medical Department and by the Marketing and International Medical Department of the Recordati Group.
   6. Your personal data will not be disseminated but may be conveyed to all entities with the right of access thereto as per law or regulations, or for purposes connected with the legal duties relating to Pharmacovigilance.
   7. The data may be processed on paper and/or computer by third parties needing to have knowledge thereof by reason of their activities or tasks for the aforesaid purposes. In such cases, said parties shall be selected from amongst those persons who, through their experience, capability and reliability, provide a suitable guarantee of compliance with the applicable rules on processing, including as concerns the security profile. Such persons are appointed as Data Processor and an up-to-date list of their names shall be available at any time upon request addressed to the Data Controller.
3. Identity of the Data Controller of the processing of personal data
   
   1. The Data Controller of the processing of your data, as per law, is RECORDATI for reports of adverse reactions relative to products of RECORDATI, INNOVA PHARMA for reports of adverse reactions relative to products of INNOVA PHARMA and ITALCHIMICI for reports of adverse reactions relative to products of ITALCHIMICI, with Headquarters at Via Matteo Civitali n° 1, 20148 Milan, Italy.
4. Authorized person for personal data processing
   
   1. The Data Controller has appointed the authorized person for personal data processing belonging to the company Departments and Divisions involved therein. Their names shall be made known as appropriate, in relation to the needs of a specific case, upon request addressed to RECORDATI/INNOVA PHARMA/ITALCHIMICI.
5. Rights of the provider of data
   
   1. Chapter III of the GDPR grants you specific rights, among which, the right to be informed of all the data concerning you that are being processed, the purposes for which they were collected and the means through which they are processed, as well as the right to rectification and erasure as per law compliance limits.
   2. You may exercise your rights as recognized by law by email to the Recordati Group DPO email address () or written communication addressed to RECORDATI/INNOVA PHARMA/ITALCHIMICI, with Headquarters at Via Matteo Civitali n° 1, 20148 Milan, Italy.

Please find here below main GDPR Articles within CHAPTER III “Rights of the data subject”
Art. 15 (1) “Right of access by the data subject”
Article 16 “Right to rectification”
Article 17 (1) “Right to erasure (‘right to be forgotten’)”
Article 18 (1) “Right to restriction of processing”
Article 19 “Notification obligation regarding rectification or erasure of personal data or restriction of processing”
Article 20 (1) “Right to data portability “
Article 21 “Right to object “
Article 22 “Automated individual decision-making, including profiling”