1.
PURPOSE OF THIS PRIVACY POLICY
1.1	NZP UK Limited (company number 02420895 and formerly
known as Dextra Laboratories Ltd) respects your privacy
and is committed to protecting your personal data. This
privacy policy aims to give you information on how wecollect and process your personal data through your use ofthis website, including any data you may provide throughthis website when you purchase a product or service,contact us via our website enquiry forms, or submit a report
to us via our whistleblowing platform.
1.2	This website is not intended for children and we do notknowingly collect data relating to children.
1.3	It is important that you read this privacy policy together withany other privacy policy or fair processing policy we may
provide on specific occasions when we are collecting orprocessing personal data about you so that you are fully
aware of how and why we are using your data. This privacy
policy supplements other notices and privacy policies and is
not intended to override them.
2.
DEFINITIONS(a)	“Comply with a legal obligation” means processing yourpersonal data where it is necessary for compliance with alegal obligation that we are subject to;(b)“External Third Parties” means:(i)	Service providers who provide, for example, IT
and system administration services;(ii)	Professional advisers including lawyers,
bankers, auditors and insurers who provide
consultancy, banking, legal, insurance andaccounting services;(iii)	HM Revenue & Customs, regulators and otherauthorities who require reporting of processing
activities in certain circumstances.
(c)	“Internal Third Parties” means other companies in the ICE
Pharma Group acting as joint controllers or processors
and who provide, for example, IT, procurement and systemadministration services;(d)	“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) andyour rights before we process your personal data for ourlegitimate 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 specificactivities by contacting us;(e)	“Performance of a 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.
3.
DATA CONTROLLER
3.1	The “contact us” section of this website, located at https://NZP UK Limited
Company number: 02420895

www.icepharma.com/nzp/, and our whistleblowing platform,
located at https://icepharma.integrityline.com/ are operated
by ICE S.p.a., with the registered address at Via Sicilia,
8/10 – 42122 Reggio Emilia, Italy. All inquiries regarding
Dextra’s business, and online purchases from Dextra, aremanaged through a separate website accessible at https://www.dextrauk.com. This is operated by NZP UK Limited
which has its registered office at One Glass Wharf, Bristol,
BS2 0ZX. When we use the terms “we”, “us” or “our” in thisprivacy policy, we are referring to the relevant company in
the ICE Pharma Group responsible, as the data controller,
for the processing of your data.
3.2	The legal department within ICE S.p.a. is responsible foroverseeing questions in relation to this privacy policy. If you
have any questions about this privacy policy, including any
requests to exercise your legal rights, please contact thelegal department using the detailsset out below.
4.
CONTACT DETAILS
4.1	If you have any questions about this privacy policy or our
privacy practices, please contact the legal department
within ICE S.p.a. in the following ways:	
Full name of legal entity: ICE S.p.a.
Email address: privacy@iceitaly.com
	Postal address: via Sicilia, 8/10 – 42122 Reggio
Emilia, Italy.
4.2	You have the right to make a complaint at any time to the
Information Commissioner’s Office (ICO), the UK regulator
for data protection issues (www.ico.org.uk). We would,
however, appreciate the chance to deal with your concerns
before you approach the ICO so please contact us in thefirst instance.
5.
THIRD-PARTY LINKS
5.1	This website may include links to third-party websites, plugins and applications. Clicking on those links or enabling
those connections may allow third parties to collect orshare data about you. We do not control these thirdparty websites and are not responsible for their privacy
statements. When you leave our website, we encourage
you to read the privacy policy of every website you visit.
6.
THE DATA WE COLLECT ABOUT YOU
6.1	Personal data, or personal information, means any
information about an individual from which that person canbe identified. It does not include data where the identity has
been removed (anonymous data).
6.2	We may collect, use, store and transfer different kinds of
personal data about you which we have grouped together
as follows:(a)“Identity Data” includes first name, last name and title.
(b) 	“Contact Data” includes billing address, delivery address,
email address and telephone numbers.
(c) 	“Financial Data” includes bank account and payment card
details.
(d) 	“Transaction Data” includes details about payments to andfrom you and other details of products and services you
have purchased from us.

Registered office address: 1 Glass Wharf, Bristol, BS2 OZXVAT number: GB250080056

(e) 	“Technical Data” includes internet protocol (IP) address,
your login data, browser type and version, time zone setting
and location, browser plug-in types and versions, operating
system and platform, and other technology on the devices
you use to access this website.
(f) 	“Profile Data” includes your username and password,purchases or orders made by you, your interests,
preferences and feedback.
(g) 	“Usage Data” includes information about how you use our
website, products and services.
(h) 	“Marketing and Communications Data” includes yourpreferences in receiving marketing from us and our third
parties and your communication preferences.
6.3	We may also collect, use and share “Aggregated Data”
such as statistical or demographic data for any purpose.
Aggregated Data could be derived from your personal data
but is not considered personal data in law as this data will
not directly or indirectly reveal your identity. For example,
we may aggregate your Usage Data to calculate thepercentage of users accessing a specific website feature.
However, if we combine or connect Aggregated Data withyour personal data so that it can directly or indirectly identify
you, we treat the combined data as personal data which will
be used in accordance with this privacy policy.
6.4	We do not collect any “Special Categories of Personal Data”
about you (this includes details about your race or ethnicity,religious or philosophical beliefs, sex life, sexual orientation,
political opinions, trade union membership, information
about your health, and genetic and biometric data). Nor do
we collect any information about criminal convictions andoffences.
7.
IF YOU FAIL TO PROVIDE PERSONAL DATA
7.1	Where we need to collect personal data by law, or under theterms of a contract we have with you, and you fail to providethat data when requested, we may not be able to performthe contract we have or are trying to enter into with you (forexample, 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 caseat the time.
8.
HOW YOUR PERSONAL DATA IS COLLECTED
8.1	We use different methods to collect data from and about
you including through:(a) 	Direct interactions. You may give us your Identity, Contact
and Financial Data by filling in forms or by corresponding
with us by post, phone, email or otherwise. This includes
personal data you provide when you:(i) purchase our products or services;(ii) create an account on our website;(iii) subscribe to our service or publications;(iv) request marketing to be sent to you;(v) give us feedback or contact us, including when you
contact us via our website enquiry forms; or(vi) as one of our suppliers, submit a report to us via ourwhistleblowing platform.

NZP UK Limited
Company number: 02420895(b)	Automated technologies or interactions. As you interact with
our website, we will automatically collect Technical Data
about your equipment, browsing actions and patterns. We
collect this personal data by using cookies, server logs andother similar technologies.
(c)	Third parties or publicly available sources. We may receive
personal data about you from various third parties andpublic sources as set out below:(i)Technical Data from the following parties:(A) analytics providers;(B) advertising networks; and(C) search information providers.
(ii) Contact, Financial and Transaction Data from providersof technical, payment and delivery services.
(iii) Identity and Contact Data from data brokers or
aggregators.
(iv) Identity and Contact Data from publicly available
sources.
9.
HOW WE USE YOUR PERSONAL DATA
9.1	We will only use your personal data when the law allows us
to. Most commonly, we will use your personal data in thefollowing circumstances:(a)	Where we need to perform the contract we are about toenter into or have entered into with you.
(b)	Where it is necessary for our legitimate interests (or thoseof a third party) and your interests and fundamental rights
do not override those interests.
(c)Where we need to comply with a legal obligation.
9.2	Generally, we do not rely on consent as a legal basis
for processing your personal data although we will getyour consent before sending third party direct marketing
communications to you via email or text message. You havethe right to withdraw consent to marketing at any time bycontacting us.
10.	PURPOSES FOR WHICH WE WILL USE YOURPERSONAL DATA
10.1	We have set out below, in a table format, a description of all
the ways we plan to use your personal data, and which of
the legal bases we rely on to do so. We have also identified
what our legitimate interests are where appropriate.
10.2	Note that we may process your personal data for more than
one lawful ground depending on the specific purpose forwhich we are using your data. Please contact us if you needdetails about the specific legal ground we are relying on toprocess your personal data where more than one groundhas been set out in the table below.

Registered office address: 1 Glass Wharf, Bristol, BS2 OZXVAT number: GB250080056

Lawful basis for processing including
basis of legitimate interest

Purpose/Activity

Type of data

To register you as a newcustomer(a) Identity(b) Contact

Performance of a contract with you

To process and deliver yourorder including:(a) Manage payments, fees
and charges(b) Collect and recover money
owed to us(a) Identity(b) Contact(c) Financial(d) Transaction(e) M arketing andCommunications(a) Performance of a contract with you(b) N ecessary for our legitimate interests (to recover debts
due to us)

To manage our relationshipwith you which will include:(a) Notifying you aboutchanges to our terms or
privacy policy(b) Responding to you when
you contact us via our
website enquiry forms(c) Dealing with any reportwhich you submit, as oneof our suppliers, to us via
our whistleblowing platform(a) Identity(b) Contact(c) Profile(d) M arketing andCommunications(a) Performance of a contract with you(b) N ecessary to comply with a legal obligation(c) N ecessary for our legitimate interests (to keep ourrecords updated, to study how customers use our
products/services and to respond to online enquiries)

To administer and protect ourbusiness and this website(including troubleshooting,data analysis, testing, system
maintenance, support,
reporting and hosting of data)(a) Identity(b) Contact(c) Technical(a) N ecessary for our legitimate interests (for running ourbusiness, provision of administration and IT services,
network security, to prevent fraud and in the context of abusiness reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation

To deliver relevant website
content and advertisements
to you and measure orunderstand the effectiveness of
the advertising we serve to you(a) Identity(b) Contact(c) Profile(d) Usage(e) M arketing andCommunications(f) Technical

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

To use data analytics to
improve our website, products/
services, marketing, customer
relationships and experiences(a) Technical(b) Usage

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

To make suggestions andrecommendations to you about
goods or services that may beof interest to you(a) Identity(b) Contact(c) Technical(d) Usage(e) Profile(f) M arketing andCommunications

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

NZP UK Limited
Company number: 02420895

Registered office address: 1 Glass Wharf, Bristol, BS2 OZXVAT number: GB250080056

11.
MARKETING
11.1	We strive to provide you with choices regarding certain
personal data uses, particularly around marketing andadvertising.
12.
PROMOTIONAL OFFERS FROM US
12.1	We may use your Identity, Contact, Technical, Usage andProfile Data to form a view on what we think you may wantor need, or what may be of interest to you. This is how we
decide which products, services and offers may be relevant
for you (we call this marketing).
12.2	You will receive marketing communications from us if you
have requested information from us or purchased goods orservices from us and you have not opted out of receivingthat marketing.
13.
THIRD-PARTY MARKETING
13.1	We will get your express opt-in consent before we shareyour personal data with any third party for marketing
purposes.
14.
OPTING OUT
14.1	You can ask us or third parties to stop sending you
marketing messages at any time by following the optout links on any marketing message sent to you or bycontacting us at any time.
14.2	Where you opt out of receiving these marketing messages,
this will not apply to personal data provided to us as aresult of a product/service purchase, warranty registration,
product/service experience or other transactions.
15.
COOKIES15.1	You can set your browser to refuse all or some browser
cookies, or to alert you when websites set or accesscookies. If you disable or refuse cookies, please note thatsome parts of this website may become inaccessible or not
function properly.

(c)	Third parties to whom we may choose to sell, transfer ormerge 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 inthis privacy policy.
17.2	We require all third parties to respect the security of yourpersonal data and to treat it in accordance with the law. We
do not allow our third-party service providers to use yourpersonal data for their own purposes and only permit themto process your personal data for specified purposes and inaccordance with our instructions.
18.
INTERNATIONAL TRANSFERS
18.1	We share your personal data within the ICE Pharma Group.
This will involve transferring your data outside the UK tomembers of the ICE Pharma Group located in the European
Economic Area (EEA) and New Zealand.
18.2	Many of our external third parties are based outside theUK so their processing of your personal data will involve atransfer of data outside the UK.
18.3	Whenever we transfer your personal data out of the UK,
we ensure a similar degree of protection is afforded to
it by ensuring at least one of the following safeguards is
implemented:(a)	We will only transfer your personal data to countries
that have been deemed to provide an adequate level ofprotection for personal data.
(b)	Where we use certain service providers, we may use
specific contracts approved for use in the UK which give
personal data the same protection it has in the UK.
18.4	Please contact us if you want further information on thespecific mechanism used by us when transferring yourpersonal data out of the UK.

16.
CHANGE OF PURPOSE
16.1	We will only use your personal data for the purposes forwhich we collected it, unless we reasonably consider that
we need to use it for another reason and that reason iscompatible with the original purpose.
16.2	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.
16.3	Please note that we may process your personal data
without your knowledge or consent, in compliance with theabove rules, where this is required or permitted by law.

19.
DATA SECURITY
19.1	We have put in place appropriate security measures toprevent your personal data from being accidentally lost,used or accessed in an unauthorised way, altered ordisclosed. In addition, we limit access to your personal data
to those employees, agents, contractors and other third
parties who have a business need to know. They will only
process your personal data on our instructions and they are
subject to a duty of confidentiality.
19.2	We have put in place procedures to deal with any
suspected personal data breach and will notify you andany applicable regulator of a breach where we are legallyrequired to do so.

17.
DISCLOSURES OF YOUR PERSONAL DATA
17.1	We may share your personal data with the parties set out
below for the purposes set out in the table Purposes forwhich we will use your personal data above.
(a)Internal Third Parties as set out in section 2 (Definitions).
(b)
External Third Parties as set out in section 2 (Definitions).

20.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
20.1	We will only retain your personal data for as long as
reasonably necessary to fulfil the purposes we collected
it for, including for the purposes of satisfying any legal,
regulatory, tax, accounting or reporting requirements. We
may retain your personal data for a longer period in the

NZP UK Limited
Company number: 02420895

Registered office address: 1 Glass Wharf, Bristol, BS2 OZXVAT number: GB250080056

event of a complaint or if we reasonably believe there is a
prospect of litigation in respect to our relationship with you.
20.2	To determine the appropriate retention period for personaldata, we consider the amount, nature and sensitivity of thepersonal data, the potential risk of harm from unauthoriseduse or disclosure of your personal data, the purposes forwhich we process your personal data and whether we
can achieve those purposes through other means, andthe applicable legal, regulatory, tax, accounting or otherrequirements.
21.
YOUR LEGAL RIGHTS
21.1	Under certain circumstances, you have rights under dataprotection laws in relation to your personal data.
21.2
You have the right to:(a)	Request access to your personal data (commonly known
as a “data subject access request”). This enables you toreceive a copy of the personal data we hold about you andto check that we are lawfully processing it.
(b)	Request correction of the personal data that we hold aboutyou. This enables you to have any incomplete or inaccurate
data we hold about you corrected, though we may need toverify the accuracy of the new data you provide to us.
(c)	Request erasure of your personal data. This 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 havethe 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 toerase your personal data to comply with local law. Note,however, that we may not always be able to comply withyour request of erasure for specific legal reasons which will
be notified to you, if applicable, at the time of your request.
(d)	Object to processing of your personal data where we arerelying 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 thisground as you feel it impacts on your fundamental rights
and freedoms. You also have the right to object where weare processing your personal data for direct marketing
purposes. In some cases, we may demonstrate that
we have compelling legitimate grounds to process yourinformation which override your rights and freedoms.
(e)	Request restriction of processing of your personal data.
This enables you to ask us to suspend the processing ofyour personal data in the following scenarios:(i) If you want us to establish the data’s accuracy.
(ii) Where our use of the data is unlawful but you do notwant us to erase it.

NZP UK Limited
Company number: 02420895(iii) Where you need us to hold the data even if we nolonger require it as you need it to establish, exercise or
defend legal claims.
(iv) You have objected to our use of your data but we needto verify whether we have overriding legitimate grounds
to use it.
(f)	Request the transfer of your personal data to you or to athird party. We will provide to you, or a third party you havechosen, your personal data in a structured, commonly used,machine-readable format. Note that this right only applies toautomated information which you initially provided consent
for us to use or where we used the information to perform acontract with you.
(g)	Withdraw consent at any time where we are relying onconsent 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 yourconsent, we may not be able to provide certain products orservices to you. We will advise you if this is the case at thetime you withdraw your consent.
21.3	If you wish to exercise any of the rights set out above,please contact us.
22.
NO FEE USUALLY REQUIRED
22.1	You will not have to pay a fee to access your personal
data (or to exercise any of the other rights). However, we
may charge a reasonable fee if your request is clearly
unfounded, repetitive or excessive. Alternatively, we could
refuse to comply with your request in these circumstances.
23.
WHAT WE MAY NEED FROM YOU
23.1	We may need to request specific information from you
to help us confirm your identity and ensure your right toaccess your personal data (or to exercise any of your otherrights). This is a security measure to ensure that personal
data is not disclosed to any person who has no right toreceive it. We may also contact you to ask you for further
information in relation to your request to speed up our
response.
24.
TIME LIMIT TO RESPOND
24.1	We will respond to all data protection access requests
as quickly as possible (usually one month unless the law
allows us more time because your request is particularlycomplex or you have made a number of requests. In thiscase, we will notify you and keep you updated).
25.	CHANGES TO THE PRIVACY POLICY AND YOUR DUTY
TO INFORM US OF CHANGES
25.1	We keep our privacy policy under regular review. Thisversion was last updated on 7 May 2024.
25.2	It is important that the personal data we hold about youis accurate and current. Please keep us informed if yourpersonal data changes during your interaction with us.

Registered office address: 1 Glass Wharf, Bristol, BS2 OZXVAT number: GB250080056