INFORMATION PURSUANT TO EU REGULATION
2016/678 (GDPR)
This information is given pursuant to art. 13 of the EuropeanRegulation 2016/679 on the protection of Personal Data (hereinafter“GDPR”) and subsequent amendments and additions and the Italianreference legislation, including Legislative Decree no.101 of August
10, 2018, by the company Ice spa – via Sicilia, 8/10 – 42122 Reggio
Emilia – vat number 01227810353 and its Indian subsidiary M/s.
Raichem Medicare Private Limited (hereinafter collectively referred
to as “Company “), in its capacity as Data Controller (or such otherrelevant term under Applicable Law), and any other applicable law for
the time being in force relating to the processing of Personal Data inIndia, as may be amended, modified, repealed and substituted fromtime to time (“Applicable Law”). The information in this Privacy Policy
is provided to those (hereinafter “you”, “user”, “visitor”, “Data Subject”
or such other relevant term under Applicable Law) who interact withthe web services of the Company accessible at the address https://www.icepharma.com (“Website”).
This information is provided with the aim of informing the user aboutthe methods of processing the relevant Personal Data.
You hereby consent to the collection, storage, use, disclosure,transfer, erasure, deletion, or otherwise processing under theApplicable Law (“Processing”) of such data or information about anindividual, who is identifiable by or in relation to such data (hereinafter,“Personal Data”) and as provided in this Privacy Policy. This Personal
Data may be collected by the Company as disclosed by you either
voluntarily (for example, by writing to the Company through the“contact” section) or by analyzing the pages you browse on theWebsite. The Personal Data Processed through the Website arespecified in the following paragraphs.
TYPES OF DATA COLLECTED AND PURPOSES
While browsing the Website, the Data Controller may acquire
information including Personal Data about the visitor, in the followingways.
1. 	BROWSING DATA
The computer systems and software procedures used to run thiswebsite acquire, during their normal operation, some data whosetransmission is implicit when using Internet communication protocols.
This data category only includes IP addresses, URI (UniformResource Identifier) addresses of the resources requested, the timeof the request, the method used to submit the request to the server,
the size of the file obtained as answer, the numerical code indicating
the status of the answer given by the server (successful, error, etc.)
and other parameters relating to the operating system and the user’s
computer environment.

immediately after Processing; currently the data on web
contacts do not persist for more than 30 days.
2. 	DATA PROVIDED VOLUNTARILY BY THE USER
The optional, explicit and voluntary sending of electronic
mail to the addresses mentioned on this Website involves
the acquisition by the Company of the sender’s email
address, and any other Personal Data eventually requested
such as name, surname, address, telephone number(landline or mobile phone), including such Personal Data
you disclose to the Company through the Website.	The Personal Data acquired in this way will be used only
to Process the user’s request; to send the information
specifically requested; to fulfil any obligations under
Applicable Law, regulations or Community legislation and tosatisfy any requests from the Authorities (tax, judicial, or any
other enforcement authorities under Applicable Law).	They will not be used for marketing purposes without yourprior express consent and will not be sold, transmitted,
given or passed on to third parties in any way.	The legal basis for the Processing of Personal Data for thepurposes set out in the preceding sections is contained invarious provisions of the Applicable Law, including among
others, Articles 6(1)(b); 6(1)(c), 6(1)(f), 9(2)(a), 9(2)(b) of EU
Regulation 2016/679.
3. 	OPTIONALITY OF DATA PROVIDINGThe user is free to not provide Personal Data, but failure
to provide such data will make it impossible to browse
the various sections of the Website or obtain any reply torequests made to the Company.
4. 	COOKIES
Cookies are used on our website to provide users with abetter service and experience. For any information about
this type of data and its Processing, please refer to thespecific section of the Website accessible at the address
https://www.icepharma.com/cookies-policy.
5. 	PROCESSING RULES AND MODALITIESPersonal Data is Processed by computer and/or telematic
tools for the time strictly necessary to achieve the purposes
for which they were collected. Specific security measures
are observed to prevent the loss of data, illicit or incorrect
use and unauthorized access.	The Processing is carried out by means of technical andorganizational methods and logic strictly related to thepurposes indicated.	This data is used for the sole purpose of obtaining
anonymous statistical information on the use of the Website
and to check its correct functioning and are deleted

6. 	DATA RECIPIENTSIn addition to the Data Controller, the data may be accessedby some internal staff tasked with Processing involvedin the organization of the Website or in the provision of24, 25, 26 & 26P, Raichur Industrial Growth Centre, Raichur Rd,
Chicksugur, Karnataka 584134, India

Phone:+91 95133 00524

www.icepharma.com/raichem

services (administrative staff, system administrators or otheremployees, all of whom are committed to confidentiality
where they are not subject to specific formal legalobligations) formally appointed as Authorized Persons tothe Data Processing i.e. external persons/entities (such as
third party technical service providers, hosting providers, ITcompanies, business partners responsible for processing
online requests or other external consultants) formallyappointed as Data Processors by the Data Controller.
The updated list of the Data Processors can always berequested from the Data Controller by sending a specificcommunication to the addresses indicated in the “Contactdetails” section of this information.for which they werecollected. Specific security measures are observed
to prevent the loss of data, illicit or incorrect use andunauthorized access.
7. 	PERSONAL DATA PROTECTION
The Data Controller has implemented a study on theimpact and risk assessment in relation to the Personal
Data Processing according to GDPR regulations: it has,
therefore, implemented specific security measures,
observed by all staff tasked with the Processing, to prevent
data loss, illegal or incorrect use and unauthorized access.
These measures take into account:- state-of-the-art technology- the costs of its implementation- the nature of the data
- the risk of Processing	The purpose is to protect them from accidental or unlawfuldestruction or alteration, accidental loss, unauthorized
disclosure or access, and other forms of unlawful
Processing. Moreover, when managing your Personal Data,
the Company:- c ollects and Processes Personal Data that are adequate,relevant and not excessive, as required to meet the above
purposes	- e
 nsures that such Personal Data remains up-to-date,accurate and appropriately erased.
8. 	RETENTION TIMES
Browsing data is deleted immediately after Processing; atpresent, web contact data is not retained for more than 30days.	Personal data is Processed by computer and/or automatedtools for the time strictly necessary to achieve the purposes
for which they were collected. The data of the User whointeracted through the section “Contacts” or “request foronline services” will be erased after 12 months from thecompletion of the last useful contact.

24, 25, 26 & 26P, Raichur Industrial Growth Centre, Raichur Rd,Chicksugur, Karnataka 584134, India

9. 	RIGHTS OF THE DATA SUBJECTAs Data Subject, you enjoy the rights contained in various
provisions of the Applicable Law, including among others,
Art. 15 et seq. GDPR, namely the following rights:	1. to obtain from the Data Controller confirmation as towhether or not your Personal Data are being Processed
and, if so, to obtain access to the Personal Data and thefollowing information: -the purposes of the Processing; -thecategories of Personal Data concerned; -the recipients or
categories of recipients to whom the Personal Data havebeen or will be disclosed, in particular if they are recipientsfrom third countries or international organizations; -wherepossible, the proposed storage period of Personal Dataor, if this is not possible, the criteria used to determinethat period -if the Data are not collected directly from theData Subject, any available information on their source;-the existence of an automated decision-making, includingprofiling and, at least in such cases, significant informationon the logic used, as well as the importance and theenvisaged consequences of such Processing for the Data
Subject; -and any other information you are authorized toobtain from the Data Controller under Applicable Law.	2. to obtain from the Data Controller the rectification,correction, completion, updating of your Personal Data
without undue delay. Taking into account the purposes ofthe Processing, the Data Subject has the right to obtain theintegration of incomplete Personal Data, even by providing
a supplementary declaration.	3. to obtain from the Data Controller the erasure of your
Personal Data without undue delay, for any of the following
reasons, whichever is earlier: (a) the Personal Data is nolonger necessary in relation to the purposes for which it
was collected or otherwise Processed; (b) the Data Subject
withdraws the consent on which the Processing is based inaccordance with various provisions of the Applicable Law,
including among others, GDPR Article 6(1)(a) or Article 9(2)(a), and if there is no other legal ground for the Processing;(c) the Data Subject objects to the Processing pursuant toGDPR Article 21(1) and there is no overriding legitimate
grounds for the Processing, or the Data Subject objects
to the Processing pursuant to GDPR Article 21(2); (d) thePersonal Data have been unlawfully Processed; (e) thePersonal Data must be erased for compliance with a legal
obligation imposed under Applicable Law, including by theUnion or Member State law to which the Data Controller
is subject; (f) the Personal Data has been collected inconnection with the offer of information society services
referred to in GDPR Article 8(1).	4. to obtain from the Data Controller the restriction of theProcessing when one of the following applies: (a) thePhone:+91 95133 00524

www.icepharma.com/raichem

accuracy of the Personal Data is contested by the Data
Subject, for a period enabling the Data Controller to verify
the accuracy of the Personal Data; (b) the Processing is
unlawful and the Data Subject opposes the erasure of
the Personal Data and requests the restriction of theiruse instead; (c) the Data Controller no longer needs thePersonal Data for Processing purposes, but the Personal
Data are necessary for the establishment, exercise or
defence of legal claims under the Applicable Law; (d) theData Subject has objected to the Processing pursuant toGDPR Art. 21(1), pending the verification as to whether thelegitimate grounds of the Data Controller prevail over thoseof the Data Subject.

CONTACT DETAILSFor any need or to exercise the rights referred to in the precedingarticle write to the Data Controller of ice s.p.a. –via sicilia, 8/10 –42122 reggio emilia or send an e-mail to privacy@icepharma.com

CHANGES TO THIS PRIVACY POLICY
Any future changes or additions to the Processing of Personal Dataas described in this Privacy Policy will be posted on the following site:
Privacy Policy – ICE Pharma	5. to receive in a structured, commonly used andmachine-readable format your Personal Data provided toa Data Controller and transmit such data to another Data
Controller without hindrance from the Data Controller towhich the Personal Data have been provided where: a)the Processing is based on consent, or on a contract or
any other grounds not prohibited under Applicable Law;b) the Processing is carried out by automated means. Inexercising his or her rights in relation to data portability,
the Data Subject has the right to have the Personal Datatransmitted directly from one Data Controller to another,where technically feasible.	6. to object at any time, on grounds relating to yourparticular situation, to the Processing of your Personal Data
pursuant to provisions under Applicable Law, including
GDPR Art. 6(1) (e) or (f), including profiling on the basis ofthose provisions.	7. not to be subject to a decision based solely on automatedProcessing, including profiling, which produces legal effects
concerning you similarly significantly affects you.	8. to have your grievances in relation to the Processing ofyour Personal Data redressed by the Data Controller within
the time period prescribed under Applicable Law. Pleaserefer to the contact details provided in this Privacy Policy, toreach out to the Company in respect of such grievances.	9. to lodge a complaint with a supervisory authority if you
are dissatisfied with our grievance redressal actions or
believe that our Processing of your Personal Data is not inaccordance with Applicable Law.	10. to nominate another individual to exercise your rights
herein provided, in the event of your death or incapacity.

24, 25, 26 & 26P, Raichur Industrial Growth Centre, Raichur Rd,
Chicksugur, Karnataka 584134, India

Phone:+91 95133 00524

www.icepharma.com/raichem